Kory D.S. 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 the plaintiff’s applications for Disability Insurance Benefits and Supplemental Security Income. The court held that the Administrative Law Judge provided legally sufficient reasons for discounting the plaintiff’s subjective symptom testimony and that any error concerning an “understanding supervisor” limitation was harmless. The court affirmed the Commissioner’s decision.

Holdings

1. The ALJ provided multiple clear and convincing reasons, supported by substantial evidence, for discounting Plaintiff's subjective symptom testimony, including evidence of improvement with treatment and conservative care.
2. Even assuming the ALJ erred by implicitly rejecting medical opinions calling for an 'understanding supervisor' without explanation, such error was harmless because this restriction is not a workable functional limitation appropriate for inclusion in an RFC or VE hypothetical.

Questions Presented

1. Whether the ALJ erred in rejecting Plaintiff's subjective symptom testimony.
2. Whether the ALJ erred at step five of the sequential evaluation by failing to account for all of Plaintiff's limitations in the hypothetical posed to the vocational expert and in the RFC.

Disposition

affirmed