Northern District of Ohio

In this case, on referral from another office, the Northern District of Ohio remanded on November 25. Although the court disagreed with our argument that the claimant met the requirements of Listing 12.05 (which I continue to adamantly disagree with), it agreed that the ALJ otherwise failed to give appropriate consideration to the claimant’s mental impairments when forming the RFC. In particular, in the Sixth Circuit, per Ealy, an ALJ should, in most situations, incorporate mental limitations from the PRT analysis particularly where, as here, the ALJ’s mental RFC was extremely nonspecific.