Allison K. D. v. Frank Bisignano

Summary

The United States District Court for the Central District of California affirmed the Commissioner of Social Security’s decision ending Plaintiff’s disability benefits as of April 1, 2016. The court held that the Administrative Law Judge properly evaluated the medical opinions, assessed Plaintiff’s residual functional capacity, and found that she could perform jobs existing in significant numbers in the national economy. The court also concluded that any error in classifying Plaintiff’s thyroid carcinoma as non-severe was harmless.

Holdings

1. The ALJ did not err in evaluating Dr. Solomon's opinions because the residual functional capacity assessment accepted and incorporated the moderate and mild limitations identified in those opinions, and Plaintiff identified no inconsistency between the RFC and Dr. Solomon's assessments.
2. The ALJ provided legally sufficient reasons supported by substantial evidence for giving little weight to Dr. Carlstroem's opinions.
3. Any error in finding that Plaintiff's papillary thyroid carcinoma was not severe at step two was harmless because the ALJ proceeded beyond step two and Plaintiff identified no functional limitations from the condition that were omitted from the RFC.
4. The Commissioner's decision that Plaintiff's disability ended on April 1, 2016, and that she had not become disabled again through December 20, 2023, was supported by substantial evidence and was not based on improper legal standards.

Questions Presented

1. Whether the ALJ improperly evaluated the opinions of treating providers Dr. Solomon and Dr. Carlstroem.
2. Whether the ALJ erred at step two by finding that Plaintiff's papillary thyroid carcinoma was not a severe impairment.
3. Whether the Commissioner's decision was supported by substantial evidence and free of legal error.

Disposition

affirmed