Hart v. Astrue
Plaintiff Robert L. Hart appealed the denial of his Supplemental Security Income (SSI) benefits application. The District Court, reviewing a Magistrate Judge's Report and Recommendation, reversed the Commissioner of Social Security's decision. Senior District Judge Thomas J. McAvoy found that the Administrative Law Judge erred by not affording controlling weight to the plaintiff's treating physician's opinion, which restricted heavy lifting to under 15 pounds, contradicting the ALJ's finding that the plaintiff could occasionally lift 20 pounds. Furthermore, the ALJ improperly afforded minimal weight to a non-medical disability analyst's opinion and failed to consult a vocational expert despite evidence of non-exertional limitations. The case was remanded for further proceedings to correctly assess the plaintiff's residual functional capacity.