Steven B. v. Commissioner Social Security Administration

Summary

The U.S. District Court for the District of Oregon reviews the Commissioner of Social Security’s denial of Steven B.’s application for Disability Insurance Benefits. The court holds that the administrative law judge did not commit harmful legal error in evaluating the Listings, medical opinion evidence, subjective symptom testimony, or step-five determination, and affirms the Commissioner’s decision. The opinion specifically addresses the materiality of Plaintiff’s substance use and his residual functional capacity if substance use ceased.

Holdings

1. The ALJ did not err in finding that Plaintiff would not meet or medically equal Listings 12.04 or 12.15 if he stopped using substances. Plaintiff failed to identify evidence establishing all required listing criteria, including the paragraph B or paragraph C criteria.
2. The ALJ reasonably found Dr. Rice's opinion unpersuasive when evaluated in the absence of substance use and other significant treatment noncompliance.
3. The ALJ provided clear and convincing reasons, supported by substantial evidence, for discounting Plaintiff's subjective symptom testimony.
4. The ALJ did not err at step five because the identified jobs require GED Reasoning Level Two, which is consistent with Plaintiff's limitation to simple, routine, and repetitive tasks, and the ALJ reasonably relied on the vocational expert's testimony regarding occasional interaction with supervisors and coworkers.

Questions Presented

1. Whether the ALJ adequately analyzed whether Plaintiff met or equaled Listings 12.04 and 12.15 absent substance use.
2. Whether the ALJ properly evaluated the persuasiveness of treating psychiatrist Joel Rice's medical opinion under the revised Social Security regulations.
3. Whether the ALJ provided legally sufficient reasons supported by substantial evidence for discounting Plaintiff's subjective symptom testimony.
4. Whether the ALJ properly resolved any conflict between Plaintiff's residual functional capacity and the reasoning and supervisory requirements of the jobs identified at step five.

Disposition

affirmed