[William N.] v. Kijakazi (E.D. Mo. Mar. 21, 2022) - migraine headaches, RFC - reliance on outdated assessments of the State agency medical consultants

[William N.] v. Kijakazi, No. 4:20 CV 1422 CDP, 2022 WL 832328 (E.D. Mo. Mar. 21, 2022) (Decision by U.S. District Judge Catherine D. Perry)

Briefs Included:  Plaintiff’s Brief, Plaintiff’s Statement of Uncontroverted Facts, and Plaintiff’s Reply Brief

Topics addressed:

• Listing - medical equivalence
• ALJ must build an accurate and logical bridge from the evidence to his conclusion
• RFC - lack of support for findings
• RFC - reliance on outdated assessments of the State agency medical consultants 
• RFC - limitations from migraine headaches 
• Subjective complaints - required findings
• Subjective complaints –  improvement does not equal the ability to work
• Migraine headaches
  

Rulings addressed:

• Social Security Ruling 96-8p

• Social Security Ruling 19-4p

 Issues briefed: 

1)  The ALJ failed to properly evaluate the impact of Plaintiff’s migraine headaches on his ability to work.

2) The ALJ’s RFC assessment, which is based solely on the outdated assessment of a State agency nonexamning medical consultant, is not supported by substantial evidence.

Court decision:
After full briefing, the court remanded for further proceedings.