Summary
This memorandum and recommendation addresses Christopher Ross Huffman’s challenge to the Commissioner of Social Security’s denial of disability insurance and supplemental security income benefits. The magistrate judge recommends affirming the Commissioner’s decision, concluding that the ALJ properly evaluated Plaintiff’s seizure disorder, applicable listing criteria, residual functional capacity, and medical opinions under the substantial-evidence standard.
Holdings
- The ALJ did not commit reversible error by evaluating Huffman's seizure disorder under Listing 11.02 rather than separately under Listing 12.07 because the ALJ considered the seizure-related symptoms while applying equivalent paragraph B criteria under Listings 12.04, 12.06, and 12.15.
- The ALJ complied with 20 C.F.R. §§ 404.1520c and 416.920c by evaluating the persuasiveness of the medical opinions based principally on supportability and consistency and by explaining why some proposed limitations were persuasive while others were not.
- The Commissioner's decision should be affirmed because the ALJ applied the correct legal standards and the factual findings were supported by substantial evidence.
Questions Presented
- Whether the ALJ erred by evaluating Huffman's seizure disorder under Listing 11.02 rather than Listing 12.07 and by failing to properly evaluate the paragraph B criteria and resulting RFC.
- Whether the ALJ complied with 20 C.F.R. §§ 404.1520c and 416.920c when evaluating the medical opinions of Ronald Koenig, M.D., Gwyneth McCawley, M.D., Nathaniel Jablecki, M.D., and Shannon Mitchell, P.A.
Disposition
other
Cases Cited (31)
- Richardson v. Perales, 402 U.S. 389, 390, 401 (1971)(followed)
- Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990)(followed)
- Smith v. Schweiker, 795 F.2d 343, 345 (4th Cir. 1986)(followed)
- Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012)(followed)
- Smith v. Heckler, 782 F.2d 1176, 1179 (4th Cir. 1986)(followed)
- King v. Califano, 599 F.2d 597, 599 (4th Cir. 1979)(followed)
- Seacrist v. Weinberger, 538 F.2d 1054, 1056-57 (4th Cir. 1976)(followed)
- Peace v. Berryhill, 2019 WL 2406626, at *1 (4th Cir. June 7, 2019)(followed)
- Brown v. Commissioner of Social Security Administration, 873 F.3d 251, 267 (4th Cir. 2017)(followed)
- Lester v. Schweiker, 683 F.2d 838, 841 (4th Cir. 1982)(followed)
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Cited In (0)
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