Kerrie S. v. Commissioner of Social Security

Summary

The United States District Court for the District of New Jersey reviews Kerrie S.’s appeal from the Commissioner of Social Security’s denial of SSD and SSI benefits. The court holds that the ALJ’s findings regarding the severity of the plaintiff’s gastrointestinal impairments and evaluation of her subjective complaints were supported by substantial evidence, or alternatively that any step-two error was harmless, and affirms the Commissioner’s decision.

Holdings

1. The ALJ's finding that Plaintiff's gastritis and ulcerative colitis were non-severe impairments was supported by substantial evidence. In any event, any step-two error was harmless because the ALJ found other severe impairments, proceeded through the remaining sequential steps, and accounted for the gastrointestinal impairments in the residual functional capacity by requiring proximate access to restroom facilities.
2. The ALJ properly evaluated Plaintiff's subjective complaints under the required two-step framework, and the resulting findings were supported by substantial evidence.

Questions Presented

1. Whether substantial evidence supported the ALJ's finding that Plaintiff's gastritis and ulcerative colitis were non-severe impairments.
2. Whether the ALJ properly evaluated Plaintiff's subjective complaints under the applicable Social Security regulations and Social Security Ruling 16-3p.

Disposition

affirmed