Bruno Moura v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Massachusetts considers Bruno Moura’s motion for judgment on the pleadings and the Commissioner of Social Security’s motion to affirm the denial of disability insurance benefits. The opinion reviews the administrative record, medical and vocational evidence, the ALJ’s residual functional capacity determination, and alleged errors concerning the evaluation of medical opinions. The document text provided ends during the court’s discussion of whether the ALJ properly evaluated the consistency of a state-agency medical consultant’s opinion.

Holdings

1. The ALJ satisfied the regulatory minimum articulation requirement for evaluating the consistency of Dr. Terlato's opinion. The ALJ's discussion of the medical record, the absence of treating-source opinions imposing additional limitations, and the absence of evidence that Moura's condition worsened adequately addressed consistency.
2. The ALJ's finding that Moura had severe depressive and anxiety disorders at Step Two was not inconsistent with relying on generally benign mental-status examinations when formulating the residual functional capacity at Step Four.
3. The Commissioner's decision denying benefits was supported by substantial evidence and contained no reversible legal error.

Questions Presented

1. Whether the ALJ adequately evaluated the consistency of the state-agency medical consultant Dr. Robert Terlato's opinion with the medical and nonmedical evidence under 20 C.F.R. § 404.1520c.
2. Whether the ALJ's characterization of Dr. Scott Haas's consultative psychological examination as generally benign was inconsistent with the finding at Step Two that Moura had severe depressive and anxiety disorders.
3. Whether the Commissioner's denial of benefits was supported by substantial evidence.

Disposition

affirmed