Frasier v. Social Security Administration, Commissioner

Plaintiff Shannon Frasier applied for Disability Insurance Benefits and Supplemental Security Income, alleging impairments including fibromyalgia, depression, and chronic pain. An administrative law judge (ALJ) denied her claim, finding she could perform her past relevant work as a cashier. Frasier appealed to the Tenth Circuit, arguing the ALJ improperly evaluated a nurse practitioner’s medical opinion and failed to properly articulate the consideration of her subjective symptom reports. The Court of Appeals, in an opinion by Judge Bacharach, held that the ALJ’s rationale was insufficient under agency regulations, as it did not adequately address the consistency and supportability of the medical opinion, and the symptom evaluation lacked the required specificity. The case was reversed in part and remanded for further proceedings before the agency.

The United States Court of Appeals for the Tenth Circuit reversed the district court’s judgment and remanded the case with instructions to return it to the Social Security Administration for a new hearing and reevaluation of the medical and symptom evidence.

Whether the ALJ properly evaluated the medical opinion evidence and the claimant's subjective symptom statements in accordance with Social Security Administration regulations, specifically the requirements for articulation of supportability and consistency.

The decision reinforced the obligation of ALJs to provide a detailed explanation when rejecting medical opinions in disability cases, thereby strengthening procedural safeguards for claimants and promoting greater transparency in administrative adjudications under the Social Security Act.