Summary
This memorandum opinion from the U.S. District Court for the Middle District of Pennsylvania reviews an Administrative Law Judge's denial of Social Security disability insurance benefits. Applying the substantial evidence standard, the court evaluates whether the ALJ properly determined that the plaintiff lacked severe medically determinable impairments during his period of insured disability. Finding that the ALJ's decision was supported by substantial evidence and based on a correct application of the law, the court affirms the Commissioner's denial.
Topics
Practice areas
Questions Presented
- Whether the ALJ’s denial of disability benefits was supported by substantial evidence.
Holdings
- The ALJ’s denial was supported by substantial evidence and is affirmed.
Key quotations
“Substantial evidence “means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,’” , 139 S. Ct. 1148, 1154 (2019).”
“The ALJ must articulate the reasons for his decision with more than just conclusory statements. 577 F.3d at 504 (3d Cir. 2009).”
Factual background
Skolny applied for disability benefits alleging alcohol dependence, paranoia, and cognitive impairments. The only contemporaneous medical record during the alleged disability period (August 2013) showed controlled GERD and no gout flare‑up. Later records (post‑2014) documented alcohol dependence and cognitive issues, but these occurred after his date last insured (December 31, 2013). The ALJ found no severe impairments and denied benefits.
Procedural history
Skolny filed a Title II disability claim which was denied by an Administrative Law Judge. The Commissioner affirmed the denial. Skolny appealed the Commissioner’s decision to the United States District Court for the Middle District of Pennsylvania.