Judge Gary Sharpe
The Social Security Administration Appeals Council denied review of an administrative law judge’s (ALJ) denial of Charlton’s applications for disability insurance benefits and supplemental security income. Noting the five-step process for evaluating if a claimant is disabled, the court agreed with Charlton that the ALJ erred, at step two, by failing to find his mental impairments severe. An ALJ’s evaluation of a claimant’s mental impairment must reflect application of the "special techniques" set out in 20 CFR §404.1520a, which in turn requires consideration of "four broad functional areas" including activities of daily living; social functioning; concentration, persistence or pace; and episodes of decompensation. Absent the required findings, the ALJ found Charlton’s intermittent explosive disorder not severe. The state agency review psychologist had failed to rate Charlton’s degree of limitation in the four functional areas. The ALJ neither mentioned those areas, nor discussed medical evidence relating to Charlton’s mental impairment, when he concluded Charlton could "perform the full range of light work. The ALJ’s errors prevented the court from meaningfully reviewing the ALJ’s determinations as to Charlton’s residual functional capacity.
