The Tenth Circuit Court of Appeals published its opinion in Chapo v. Astrue on Tuesday, June 26, 2012.
The Tenth Circuit reversed and remanded the district court’s decision. Petitioner “appeals from a district court order upholding the Commissioner’s denial of her application for disability and supplemental security income benefits.” Petitioner contends that the administrative law judge’s residual functional capacity (RFC) “determination was not supported by substantial evidence, in particular by medical opinion evidence directly supporting the RFC findings, and . . . the ALJ improperly handled the opinion evidence in the case.”
The Court found that her first contention “rests on an unduly narrow view of the role of the administrative factfinder in social security disability proceedings.” “There is no requirement in the regulations for a direct correspondence between an RFC finding and a specific medical opinion on the functional capacity in question.” Her second contention, however, has merit,” and led the Court to reverse and remand this matter to the agency for further proceedings. “[T]he ALJ’s handling of Dr. Vega’s findings was erroneous and, as a result, the dispositive hypothetical inquiry put to the [vocational expert] was fatally defective.”