Doris B. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of New Jersey reviews the Commissioner of Social Security’s denial of Doris B.’s applications for Disability Insurance Benefits and Supplemental Security Income. The court holds that the administrative law judge’s residual functional capacity determination and denial of benefits are supported by substantial evidence and affirms the Commissioner’s decision.

Holdings

1. The ALJ's RFC determination was supported by substantial evidence because the decision discussed the relevant medical and other evidence, addressed Plaintiff's physical and mental limitations, and explained the resulting exertional and nonexertional restrictions.
2. The ALJ was not required to use a particular function-by-function format and reasonably accounted for Plaintiff's carpal tunnel syndrome by limiting her to frequent, rather than constant, handling, fingering, and feeling.
3. The limitation to understanding, remembering, and carrying out simple instructions, together with occasional interaction with supervisors, coworkers, and the public, adequately addressed the supported mental limitations.
4. The ALJ was not required to include off-task time or unscheduled breaks that were not credibly established by the record.

Questions Presented

1. Whether substantial evidence supported the ALJ's residual functional capacity assessment.
2. Whether the ALJ adequately considered Plaintiff's physical impairments, including bilateral carpal tunnel syndrome, and reasonably limited her to frequent handling, fingering, and feeling.
3. Whether the ALJ adequately accommodated Plaintiff's moderate mental-functioning limitations by limiting her to simple instructions and occasional workplace interaction.
4. Whether the ALJ was required to include alleged off-task time and unscheduled breaks in the RFC or vocational hypothetical.

Disposition

affirmed