Shannon Marie Schurman v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Nevada denied Shannon Marie Schurman's request to reverse or remand the denial of her Social Security disability benefits. The court held that the Administrative Law Judge's evaluation of medical expert Dr. Jill Silverman's opinion, including opinions concerning standing, walking, and absenteeism, was supported by substantial evidence. The court affirmed the ALJ's decision and directed the clerk to enter final judgment and close the case.

Holdings

1. The ALJ reasonably discounted Dr. Silverman’s opinion concerning Schurman’s standing and walking limitations because it was inconsistent with the medical record, including the benefits from lumbar injections, equivocal straight-leg-raise findings, normal strength and sensation, and generally mild lumbar imaging findings.
2. The ALJ reasonably discounted Dr. Silverman’s opinion that Schurman would have difficulty getting to work several days per month because the medical record reflected generally routine and conservative treatment and daily activities inconsistent with the asserted severity of her limitations.
3. The ALJ did not err by discounting portions of Dr. Silverman’s opinion because an ALJ may independently review and draw conclusions from medical evidence and may reject a medical opinion when expressly providing clear and convincing reasons supported by the record.

Questions Presented

1. Whether substantial evidence supported the ALJ’s discounting of Dr. Silverman’s opinion concerning Schurman’s standing and walking limitations.
2. Whether substantial evidence supported the ALJ’s discounting of Dr. Silverman’s opinion concerning Schurman’s potential work absenteeism.
3. Whether the ALJ improperly substituted a lay medical opinion for medical expertise when discounting portions of Dr. Silverman’s opinion.

Disposition

affirmed