Alexander P. v. Commissioner, Social Security Administration

Summary

The United States District Court for the District of Oregon reviewed the Commissioner of Social Security’s denial of Alexander P.’s application for disability insurance benefits. The court rejected challenges concerning Listing 12.05B, subjective symptom testimony, and the evaluation of medical opinions, holding that the administrative law judge’s findings were supported by substantial evidence. The Commissioner’s decision was affirmed.

Holdings

1. The ALJ did not err in finding that Plaintiff failed to satisfy Listing 12.05B because the record supported only moderate limitations, rather than one extreme limitation or two marked limitations, in the relevant areas of adaptive functioning.
2. The ALJ gave specific, clear, and convincing reasons supported by substantial evidence for finding that Plaintiff's statements concerning the intensity, persistence, and limiting effects of his symptoms were not entirely consistent with the record.
3. The ALJ did not err in finding Dr. Hickman's opinion partially persuasive and Ms. Castillo's opinion unpersuasive because the ALJ adequately considered supportability and consistency and explained the findings with substantial evidence.

Questions Presented

1. Whether the ALJ erred by finding that Plaintiff's impairments did not meet or equal Listing 12.05B.
2. Whether the ALJ provided specific, clear, and convincing reasons supported by substantial evidence for discounting Plaintiff's subjective symptom testimony.
3. Whether the ALJ properly evaluated the persuasiveness of the medical opinions of David Hickman, Ph.D., and Karina Castillo, LCSW, in assessing Plaintiff's residual functional capacity.

Disposition

affirmed