Curry v. Social Security Administration, Commissioner

Tiffany Curry applied for Social Security Disability Insurance and Supplemental Security Income, alleging disabling back disorders, fibromyalgia, depression, and other impairments. An Administrative Law Judge denied her claims, finding she retained the residual functional capacity to perform her past relevant work and other jobs. The district court affirmed the Commissioner's decision. On appeal, the United States Court of Appeals for the Eleventh Circuit examined whether the ALJ properly evaluated Curry's subjective symptom testimony and incorporated all supported limitations into the RFC. The court determined the ALJ failed to articulate adequate reasons for discounting Curry's complaints of pain and fatigue and did not sufficiently explain how certain medical evidence translated into the RFC findings. Consequently, the panel vacated the district court's order and remanded the case for further administrative proceedings.

The Eleventh Circuit vacated the district court's judgment and remanded the case with instructions to return it to the Commissioner of Social Security for further evaluation consistent with the opinion.

Whether the Administrative Law Judge properly evaluated the plaintiff's subjective complaints of pain and other symptoms, and whether the residual functional capacity determination was supported by substantial evidence after properly considering all limitations.

The ruling reinforces the obligation of administrative law judges to provide a clear and specific rationale when discrediting a claimant's subjective symptom testimony, and to ensure all medically determinable impairments and related limitations are accurately reflected in the residual functional capacity assessment. It serves as a critical check on boilerplate decision-making in disability hearings and affects how similar claims are adjudicated across the Eleventh Circuit.