Brian R. v. Commissioner of Social Security

Summary

The United States District Court for the District of New Jersey reviews Brian R.’s appeal from the denial of Disability Insurance Benefits and Supplemental Security Income. The court holds that the Administrative Law Judge properly evaluated the alleged neuropathy, obstructive sleep apnea, lumbar degenerative disc disease, medical opinions, and residual functional capacity. The court affirms the Commissioner’s decision finding that Plaintiff was not disabled under the Social Security Act.

Holdings

1. The ALJ permissibly found that Plaintiff's neuropathy and obstructive sleep apnea were not severe impairments because the record did not establish persistent, significant functional limitations supported by objective evidence.
2. The ALJ adequately considered Plaintiff's medically determinable impairments, including non-severe impairments, and was not required to include limitations that were not credibly established by the record.
3. The ALJ adequately evaluated and explained the persuasiveness of the opinions of Drs. Blank, Lesneski, Atlas, and David, and substantial evidence supported the conclusions to discount or partially credit those opinions.

Questions Presented

1. Whether the ALJ erred by finding Plaintiff's neuropathy and obstructive sleep apnea non-severe at step two.
2. Whether the ALJ failed to account for alleged limitations from neuropathy and obstructive sleep apnea in the residual functional capacity assessment.
3. Whether the ALJ improperly evaluated the medical opinions of Drs. Blank, Lesneski, Atlas, and David.

Disposition

affirmed