Andrea K. v. Commissioner of Social Security

Summary

The United States District Court for the District of Maryland affirms the Commissioner of Social Security’s denial of Andrea K.’s application for Supplemental Security Income. The court rejects the claimant’s argument that the Administrative Law Judge improperly relied on lay opinion in assessing residual functional capacity and concludes that substantial evidence supported the step-five vocational finding.

Holdings

1. The ALJ did not impermissibly play doctor or substitute a lay opinion for medical expertise. The ALJ properly evaluated the medical and other evidence, explained why the state-agency opinions were unpersuasive, and independently assessed residual functional capacity as required by the regulations.
2. The ALJ did not err in finding that work existed in significant numbers in the national economy that Plaintiff could perform. Even accepting Plaintiff's estimates and excluding the allegedly obsolete nut-sorter occupation, the remaining jobs substantially exceeded numbers previously accepted as significant.

Questions Presented

1. Whether the ALJ improperly substituted a lay medical opinion for medical evidence when assessing Plaintiff's residual functional capacity.
2. Whether the ALJ's step-five finding was unsupported by substantial evidence because the vocational expert's job numbers allegedly did not correspond to the cited occupations.

Disposition

affirmed