Dirk N. vanMerkestyn v. Commissioner of Social Security Administration

Summary

The United States District Court for the District of Arizona adopted the magistrate judge’s Report and Recommendation and affirmed the denial of Dirk N. vanMerkestyn’s application for Social Security Disability Insurance benefits. The court held that the administrative law judge provided sufficient reasons for discounting vanMerkestyn’s symptom testimony and the assessments of treating counselor David Jones, LCSW. The court ordered entry of final judgment and closure of the case.

Holdings

1. The ALJ provided specific, clear, and convincing reasons for rejecting vanMerkestyn's testimony regarding the severity of his symptoms because his documented daily activities, travel, studies, hobbies, and other activities were inconsistent with his assertion that he needed to spend all day in bed.
2. The ALJ adequately explained and supported the decision to discount Jones's assessments because they were primarily unexplained check-box forms and were inconsistent with Jones's treatment notes, the consultative examination, and vanMerkestyn's daily activities.

Questions Presented

1. Whether the ALJ provided legally sufficient reasons for rejecting vanMerkestyn's testimony concerning the severity of his symptoms.
2. Whether the ALJ adequately explained and supported the decision to discount the medical-opinion assessments completed by David Jones, LCSW.

Disposition

affirmed