Niles v. Astrue
Plaintiff Gary A. Niles applied for disability insurance benefits under the Social Security Act, alleging inability to work since November 2004 due to a spinal condition, depression, and anxiety. The Commissioner of Social Security denied his application, a decision which was upheld twice by an Administrative Law Judge (ALJ), with an interim remand by the Appeals Council. Plaintiff commenced this action seeking judicial review of the Commissioner's final decision. The Magistrate Judge identified errors in the ALJ's decision concerning the evaluation of the severity of Plaintiff's impairments (insomnia, sleep apnea, obesity), the determination of whether his impairments met or medically equaled Listing § 1.04A, and the assessment of his Residual Functional Capacity (RFC) regarding prolonged sitting. The Court granted Plaintiff's motion for judgment on the pleadings, denied the Commissioner's motion, and remanded the case for further administrative proceedings to address these deficiencies, particularly regarding the treating physicians' opinions and Plaintiff's credibility concerning sitting limitations.