Vilma R. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Connecticut reviews Vilma R.’s challenge to the Commissioner of Social Security’s denial of supplemental security income benefits. The court concludes that the Administrative Law Judge applied the correct legal standards and that the decision was supported by substantial evidence, including the evaluation of the claimant’s impairments, medical opinions, residual functional capacity, and step-five findings. The court therefore affirms the Commissioner’s decision.

Holdings

1. The ALJ did not err by declining to identify certain alleged impairments as severe or by finding migraines, left epicondylitis, and fecal incontinence nonsevere because plaintiff did not show that those impairments significantly limited basic work activities for the required continuous twelve-month period.
2. The ALJ did not err in evaluating plaintiff's spinal impairment or in determining that her impairments did not meet or medically equal Listings 1.15 or 1.16.
3. The ALJ properly evaluated the medical and psychological opinions by considering their supportability and consistency and reasonably found the extreme restrictions offered by Dr. Kimmel and physical therapist Carroll unpersuasive while finding the state-agency opinions generally persuasive.
4. The ALJ's residual functional capacity finding was supported by substantial evidence.
5. The ALJ satisfied the step-five burden because the hypothetical posed to the vocational expert mirrored the RFC, the vocational expert identified occupations plaintiff could perform, and plaintiff failed to establish a conflict between the testimony and the Dictionary of Occupational Titles.

Questions Presented

1. Whether the ALJ failed to consider all of plaintiff's medically determinable impairments or improperly found migraines, left epicondylitis, and fecal incontinence nonsevere at step two.
2. Whether the ALJ properly evaluated plaintiff's spinal impairment and adequately explained the step-three listings determination.
3. Whether the ALJ properly evaluated the persuasiveness of treating-source, physical-therapist, and state-agency medical and psychological opinions under 20 C.F.R. § 416.920c.
4. Whether the ALJ's residual functional capacity finding was supported by substantial evidence.
5. Whether the ALJ satisfied the step-five burden by relying on vocational-expert testimony identifying jobs plaintiff could perform.

Disposition

affirmed