Paula W. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Central District of Illinois affirmed the Commissioner of Social Security’s denial of Paula W.’s applications for disability and supplemental security income benefits. The court held that the administrative law judge was not required to obtain another medical opinion regarding later-submitted knee-related evidence and that approximately 30,300 jobs in the national economy constituted a significant number at step five of the disability evaluation.

Holdings

1. The ALJ was not required to solicit another medical opinion because the later-submitted treatment notes, recommendations, and MRI did not constitute potential decisive evidence or materially change the picture of Paula's medical conditions.
2. Approximately 30,300 jobs in five occupations in the national economy constituted a significant number of jobs, and the Commissioner satisfied the step-five burden.

Questions Presented

1. Whether the ALJ was required to obtain an additional medical opinion to interpret medical evidence submitted after the state-agency consultants issued their opinions.
2. Whether approximately 30,300 jobs in the national economy constituted a significant number of jobs sufficient to satisfy the Commissioner's step-five burden.

Disposition

affirmed