Angella M. K. v. Commissioner Social Security Administration

Summary

The United States District Court for the District of Oregon affirmed the Commissioner of Social Security’s decision denying Angella M. K.’s application for disability benefits. The court held that the Administrative Law Judge properly evaluated the consultative psychologist’s limitations, the therapist’s opinions, and the plaintiff’s subjective symptom testimony. The court concluded that the residual functional capacity determination was supported by substantial evidence and that the ALJ did not err at step five.

Holdings

1. The ALJ did not err by translating Dr. Alvord's clinical findings into the RFC and vocational-expert hypothetical through limitations such as occasional direct interaction with the public, coworkers, and supervisors and no fast-paced or production work.
2. The ALJ did not err in finding Richards's opinions unpersuasive because they were not well supported by her treatment notes and were inconsistent with the overall record.
3. The ALJ provided specific, clear, and convincing reasons for discounting Plaintiff's testimony that fibromyalgia and arthritis limited her to sitting or standing for approximately 10 to 15 minutes at a time.
4. The ALJ provided specific, clear, and convincing reasons for discounting Plaintiff's testimony concerning social-interaction and concentration limitations.

Questions Presented

1. Whether the ALJ adequately translated Dr. Scott Alvord's moderate psychological limitations into the RFC and vocational-hypothetical limitations.
2. Whether the ALJ properly found Kimberly Richards's opinions unpersuasive based on their lack of supportability and consistency with the record.
3. Whether the ALJ provided specific, clear, and convincing reasons for discounting Plaintiff's subjective symptom testimony concerning sitting, standing, social interaction, and concentration.
4. Whether the RFC and step-five determination were supported by substantial evidence.

Disposition

affirmed