Frederick T. v. Commissioner of Social Security

Summary

The United States District Court for the District of New Jersey affirmed the Commissioner of Social Security’s denial of Frederick T.’s application for disability insurance benefits. The court held that the Administrative Law Judge adequately evaluated the alleged impairments at Step Two and supported the residual functional capacity determination with substantial evidence. The court also concluded that any potential errors in classifying certain impairments were harmless because their symptoms were considered in the RFC assessment.

Holdings

1. Any technical omission or misclassification at Step Two was harmless because the ALJ found other severe impairments, continued through the sequential analysis, and considered the symptoms and functional effects of the challenged conditions in determining the residual functional capacity.
2. The ALJ's RFC determination was supported by substantial evidence.
3. The ALJ adequately evaluated the medical opinions by addressing their supportability and consistency, and the rejection of the opinions was supported by substantial evidence.
4. The ALJ properly discounted the alleged intensity, persistence, and limiting effects of Frederick's symptoms because his statements were not fully consistent with the medical and other evidence.

Questions Presented

1. Whether the ALJ properly assessed Frederick's medically determinable impairments and the severity or determinability of his alleged immunoglobulin A deficiency, migraines, chronic fatigue syndrome, and obsessive-compulsive disorder.
2. Whether the ALJ's residual functional capacity determination was supported by substantial evidence.
3. Whether the ALJ properly evaluated the medical opinions of Dr. Charles Peeples and therapist Anne Scherbina.
4. Whether the ALJ properly evaluated Frederick's subjective testimony concerning the intensity, persistence, and limiting effects of his symptoms.

Disposition

affirmed