Richard H. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Minnesota reviewed a magistrate judge’s recommendation to dismiss a Social Security disability benefits appeal. The court overruled the plaintiff’s objection, accepted the Report and Recommendation, denied relief, and dismissed the complaint with prejudice, concluding that the Administrative Law Judge’s decision was supported by substantial evidence.

Holdings

1. An ALJ is not required to adopt the exact limitations set forth in medical opinions the ALJ finds persuasive, so the omission of the word "superficial" did not alone require reversal.
2. The ALJ's decision was supported by substantial evidence, and the court therefore affirmed the decision and dismissed the complaint with prejudice.

Questions Presented

1. Whether the ALJ's limitation to occasional interaction with supervisors and coworkers was inconsistent with persuasive medical opinions describing limited, superficial, and infrequent supervisory contact.
2. Whether the ALJ's decision was supported by substantial evidence and free of legal error.
3. Whether the magistrate judge's recommendation to dismiss the complaint should be accepted after de novo review.

Disposition

dismissed