Summary
The United States District Court for the District of Rhode Island reviewed the denial of Jared T.'s applications for Supplemental Security Income and Social Security Disability Insurance. The court held that the Administrative Law Judge's residual functional capacity determination was supported by substantial evidence, including the finding that Jared could perform simple, routine, and repetitive work despite moderate limitations in concentration, persistence, or pace. The court denied the plaintiff's motion to reverse, granted the Commissioner's motion to affirm, and directed entry of final judgment for the defendant.
Topics
Practice areas
Questions Presented
- Whether the ALJ's residual functional capacity finding was supported by substantial evidence.
- Whether the ALJ was required to impose a more restrictive residual functional capacity because he found a moderate Step Three limitation in concentrating, persisting, or maintaining pace.
- Whether the ALJ improperly disregarded or cherry-picked findings from a prior consultative psychological evaluation.
Holdings
- A moderate limitation in concentrating, persisting, or maintaining pace does not automatically translate into a work-preclusive or more restrictive RFC limitation; the ALJ must assess the claimant's functional capacity based on the evidence as a whole.
- The ALJ's RFC determination was supported by substantial evidence, and the plaintiff failed to demonstrate reversible error.
- The ALJ properly considered the consultative examination as other medical evidence and was not required to specifically articulate how he considered every item of objective or other medical evidence.
Key quotations
“Furthermore, a moderate limitation in concentrating, persisting, or maintaining pace “does not translate to a per se work preclusive RFC limit.”” (III. ANALYSIS)
“The Court does not reinterpret or reweigh the evidence or otherwise substitute its own judgment for that of the Commissioner.” (II. STANDARD OF REVIEW)
“For the reasons discussed herein, Plaintiff’s Motion to Reverse the Decision of the Commissioner (ECF No. 13) is DENIED and Defendant’s Motion to Affirm the Commissioner’s Decision (ECF No. 15) is GRANTED.” (IV. CONCLUSION)
Factual background
Jared T. is a 35-year-old claimant with anxiety, depression, rheumatic arthritis, and Lyme disease. The ALJ found at Step Three that he had a moderate limitation in concentrating, persisting, or maintaining pace, but determined that he retained the residual functional capacity for light work with physical, environmental, social, and mental limitations, including simple, routine, repetitive tasks and no production-rate work. The ALJ relied on generally benign mental-status examinations, evidence that Jared was redirectable when distracted, and state-agency psychological opinions that he could perform basic simple, routine, repetitive tasks.
Procedural history
Jared T. applied for SSDI and SSI, and the claims were denied initially and on reconsideration. After an administrative hearing, the ALJ issued an unfavorable decision, and the Appeals Council denied review. Jared filed suit under 42 U.S.C. § 405(g), moved to reverse the Commissioner's decision, and the Commissioner moved to affirm.