B.S.H. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Colorado affirmed the Commissioner of Social Security’s decision denying the plaintiff disability insurance benefits. The court held that the administrative law judge properly evaluated the plaintiff’s subjective complaints and supported the residual functional capacity determination with substantial evidence.

Holdings

1. The ALJ did not err in evaluating plaintiff's subjective complaints because he considered the evidence as a whole, including her activities, conservative treatment, and improvement with treatment, and adequately linked his conclusions to the record.
2. The ALJ did not err by omitting a limitation on plaintiff's ability to interact with the public because plaintiff identified no record evidence, apart from her own statements, supporting such a limitation, and the evidence showed that her depression was controlled and her principal mental complaints were addressed by the RFC.
3. The Commissioner's conclusion that plaintiff was not disabled was supported by the correct legal standards and substantial evidence and was affirmed.

Questions Presented

1. Whether the ALJ properly evaluated plaintiff's subjective complaints concerning the functional effects of her impairments.
2. Whether substantial evidence supported the ALJ's assessment of plaintiff's subjective complaints despite the ALJ's characterization of her daily activities.
3. Whether the ALJ erred by omitting a limitation on plaintiff's ability to interact with the public from the residual functional capacity determination.

Disposition

affirmed