Timothy Kay H. v. Commissioner of Social Security

Summary

The United States District Court for the District of Idaho reviews the denial of Timothy Kay H.'s application for Social Security disability insurance benefits. The court holds that the Administrative Law Judge provided sufficient reasons for discounting the claimant's subjective symptom testimony and adequately evaluated the treating provider's opinion concerning additional work limitations. The court affirms the administrative decision and denies remand.

Holdings

1. The ALJ properly discounted Plaintiff's subjective symptom testimony because the ALJ identified clear and convincing reasons supported by substantial evidence, including inconsistency with objective medical evidence, improvement with treatment, inconsistent daily activities, and a significant treatment gap.
2. The ALJ properly found Amanda Thompson's opinion unpersuasive under the supportability and consistency factors and was not required to include unscheduled breaks, reclining periods, frequent absences, or additional cognitive limitations in the RFC because those limitations were not supported by the record.

Questions Presented

1. Whether the ALJ provided legally sufficient, clear and convincing reasons supported by substantial evidence for discounting Plaintiff's subjective symptom testimony.
2. Whether the ALJ properly evaluated Amanda Thompson, FNP-C's medical-source opinion under the post-2017 regulations and whether the RFC adequately included limitations supported by the record.

Disposition

affirmed