[William N.] v. Kijakazi

E.D. Mo. Mar. 21, 2022

Migraine headaches, RFC - reliance on outdated assessments of the State agency medical consultants

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About this case

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RFC - reliance on outdated assessments of the State agency medical consultants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2) The ALJ’s RFC assessment, which is based solely on the outdated assessment of a State agency nonexamning medical consultant, is not supported by substantial evidence.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