Christos T. v. Commissioner of Social Security

Summary

The United States District Court for the District of New Jersey reviewed a challenge to the Commissioner of Social Security’s denial of Christos T.’s application for disability benefits. The court held that the Administrative Law Judge’s findings concerning the severity of plaintiff’s impairments, residual functional capacity, medical opinions, and ability to perform past or other work were supported by substantial evidence. The court affirmed the Commissioner’s decision.

Holdings

1. The step-two determination was supported by substantial evidence. The ALJ properly evaluated the four paragraph-B functional domains and reasonably found only mild limitations, and any error in classifying another impairment as non-severe would have been harmless because the ALJ found other severe impairments.
2. The RFC assessment was supported by substantial evidence because the ALJ considered plaintiff's medical history, reported limitations and activities, testimony, and medical opinions, including evidence concerning depression and fatigue.
3. The ALJ properly found Dr. Spisak-Mosher's opinion unpersuasive by addressing its supportability and consistency with the record.
4. The ALJ's findings that plaintiff could perform past relevant work as a data processing manager and could perform other work were sustained.

Questions Presented

1. Whether the ALJ's step-two finding that plaintiff's mental impairments, including depression, were non-severe was supported by substantial evidence.
2. Whether the ALJ's residual functional capacity assessment adequately considered plaintiff's depression, fatigue, cognitive symptoms, testimony, and medical evidence and was supported by substantial evidence.
3. Whether the ALJ properly evaluated the persuasiveness of Dr. Spisak-Mosher's medical opinion under 20 C.F.R. § 404.1520c.
4. Whether the ALJ's step-four finding that plaintiff could perform past relevant work and step-five finding that plaintiff could perform other work were supported by substantial evidence.

Disposition

affirmed