Claire C. v. Frank Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the District of Rhode Island reviewed an administrative denial of Supplemental Security Income benefits. The court rejected the plaintiff’s challenges concerning the evaluation of non-examining experts’ findings, the severity of rosacea with vision complications, and the failure to order additional cognitive testing. The court denied the plaintiff’s motion to reverse, granted the Commissioner’s motion to affirm, and directed entry of judgment for the defendant.

Holdings

1. The ALJ adequately considered the supportability and consistency of the non-examining experts' prior administrative findings, even though he did not use the words "supportability" and "consistency."
2. The ALJ did not err in finding rosacea with vision complications non-severe during the relevant period.
3. The ALJ did not abuse his discretion by declining to order additional cognitive or IQ testing.

Questions Presented

1. Whether the ALJ adequately considered the supportability and consistency of the non-examining experts' prior administrative medical findings despite not using those precise terms.
2. Whether the ALJ erred at Step Two by finding rosacea with vision complications non-severe.
3. Whether the ALJ abused his discretion by declining to order an additional consultative examination for cognitive or IQ testing.

Disposition

affirmed