Jason Hutton v. Michael Astrue
Opinion
Opinion
MEMORANDUM
Hutton appeals the decision of the district court affirming the determination of the administrative law judge (“ALJ”) denying Hutton’s application for a period of disability and disability insurance benefits. The ALJ committed legal error by failing to consider appropriately relevant lay testimony and in failing to include Hutton’s post-traumatic stress disorder (“PTSD”) in his assessment of Hutton’s residual functional capacity (“RFC”) analysis at Step Four and in his hypotheticals to the vocational expert at Step Five.
The ALJ first considered Hutton’s PTSD at Step Two of the disability analysis. There, he evaluated the limitations that Hutton’s PTSD generated via the four functional areas outlined in 20 C.F.R. § 404 .1520a(e)(3) (i.e. activities of daily living; social functioning; concentration, persistence, or pace; and episodes of decom-pensation). Based on Dr. Gregg’s opinion, the ALJ found Hutton suffered no limitation with respect to daily activities or social functioning, “mild” limitations in the area of concentration, persistence, or pace, and no episodes of decompensation. Thus, he determined that Hutton’s PTSD existed but was “nonsevere.”