Saterlee v. Astrue, No. 11-5054 (10th Cir. 2011)
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Plaintiff Donna Saterlee appealed a district court order that affirmed the Commissioner of Social Security's decision to deny social security disability and supplemental security income benefits. The Administrative Law Judge (ALJ) denied benefits at the last step of the five-step process for determining disability. Plaintiff argued that the ALJ erred by (1) improperly rejecting her hand impairment as medically nondeterminable at step two and consequently not including it in the RFC that formed the basis of the dispositive hypothetical to the Vocational Expert; and (2) failing to perform a proper credibility analysis in determining that complaints of limitations other than, or in excess of, those later included in the RFC were not credible. The Tenth Circuit found that the ALJ was "undeniably wrong" about the lack of documented medical evidence of Plaintiff's condition that gave rise to the alleged numbness, "undercutting the categorical rejection of such an impairment on this threshold basis." The Court remanded the case for an administrative decision that properly accounted for all of the evidence of record.
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