Johnathan G. v. Frank Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the District of New Mexico denies Plaintiff Johnathan G.’s motion to remand and affirms the Commissioner of the Social Security Administration’s denial of SSDI and SSI benefits. The court concludes that the ALJ adequately evaluated Plaintiff’s subjective symptoms, the alleged need for a handheld assistive device, and his non-severe mental impairments, and that the decision was supported by substantial evidence.

Holdings

1. The ALJ adequately evaluated the intensity, persistence, and limiting effects of Plaintiff's symptoms, provided a reasoned explanation linked to evidence in the record, and reached findings supported by substantial evidence.
2. The ALJ's explanation that the evidence did not establish the medical necessity of a cane or walker satisfied the minimum articulation requirement, and remand was not warranted.
3. The ALJ adequately considered Plaintiff's non-severe anxiety and post-traumatic stress disorder, and the omission of additional mental restrictions from the RFC did not require reversal.

Questions Presented

1. Whether the ALJ adequately evaluated Plaintiff's subjective symptom allegations and whether that evaluation was supported by substantial evidence.
2. Whether the ALJ adequately explained the determination that a cane or walker was not medically necessary and therefore need not be included in the residual functional capacity.
3. Whether the ALJ adequately considered Plaintiff's non-severe anxiety and post-traumatic stress disorder when formulating the residual functional capacity.

Disposition

affirmed