Jamie C. 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 Jamie C.’s claim for Disability Insurance Benefits. The court held that any omission of conversion disorder at step two was harmless because the ALJ found other severe impairments and proceeded through the sequential evaluation. The court further concluded that the ALJ adequately considered the plaintiff’s impairments, medical evidence, residual functional capacity, and vocational evidence, and that the decision was supported by substantial evidence.

Holdings

1. Any omission of conversion disorder from the step-two findings was harmless because the ALJ found multiple other severe impairments and proceeded through the remaining steps of the sequential evaluation.
2. The ALJ's step-three analysis was legally sufficient and supported by substantial evidence even though it did not expressly cite Listing 12.07.
3. The ALJ's findings, including the residual functional capacity and determination that Plaintiff was not disabled, were supported by substantial evidence.
4. The ALJ did not err by declining to obtain additional medical-expert testimony.

Questions Presented

1. Whether the ALJ committed reversible error by failing to identify conversion disorder as a severe impairment at step two.
2. Whether the ALJ inadequately evaluated conversion disorder and Plaintiff's combined impairments at step three by not expressly citing Listing 12.07.
3. Whether the ALJ's findings concerning Dr. Greco's records, acute disseminated encephalomyelitis, medication effects, aggravating factors, and residual functional capacity were supported by substantial evidence.
4. Whether the ALJ erred by declining to obtain additional medical-expert testimony.

Disposition

affirmed