Stephanie Aleman M. v. Leland Dudek, Acting Commissioner of Social Security

Summary

The United States District Court for the Central District of California affirmed the denial of Stephanie Aleman Medina’s applications for Social Security disability insurance benefits and supplemental security income. The court rejected challenges concerning the severity and functional effects of her visual impairments, evaluation of a consultative examiner’s statements, assessment of her subjective symptom testimony regarding diabetic polyneuropathy, and an alleged conflict between vocational-expert testimony and the Dictionary of Occupational Titles.

Holdings

1. The ALJ did not err in finding Plaintiff's visual impairments nonsevere and in determining that they did not warrant work-related restrictions. Even assuming error at step two, any error was harmless because Plaintiff identified no supported additional visual limitation that would have prevented her from performing her past work as a photographer.
2. The ALJ properly evaluated Dr. Lim's exertional, postural, and pushing-and-pulling limitations and did not err in declining to treat his nonspecific statement that Plaintiff had visual limitations in the left eye as a medical opinion requiring evaluation.
3. The ALJ properly partially discounted Plaintiff's subjective symptom statements and testimony concerning diabetic polyneuropathy.
4. The ALJ properly resolved the apparent conflict between the vocational expert's testimony and the DOT and reasonably relied on the expert's testimony that Plaintiff could perform her past relevant work as a photographer.

Questions Presented

1. Whether the ALJ erred by finding Plaintiff's cataract and diabetic-retinopathy-related visual impairments nonsevere and by omitting visual restrictions from the RFC.
2. Whether the ALJ properly evaluated consultative internist Seung Ha Lim's statements, including his statement that Plaintiff had visual limitations in the left eye.
3. Whether the ALJ properly evaluated Plaintiff's subjective symptom statements and testimony concerning diabetic polyneuropathy.
4. Whether the ALJ properly resolved the apparent conflict between the vocational expert's testimony that Plaintiff could perform her past work as a photographer and the Dictionary of Occupational Titles' frequent-reaching requirement.

Disposition

affirmed