Richard P. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Utah reviewed a Social Security disability insurance benefits denial under 42 U.S.C. § 405(g). The court held that the ALJ's determination that Plaintiff was not disabled, including the rejection of a proposed closed period of disability, was supported by substantial evidence and free from reversible error. The court denied Plaintiff's motion for review and affirmed the Commissioner's decision.

Holdings

1. The court held that the ALJ was not obligated to consider a closed period of disability where Plaintiff did not request that relief before the ALJ, particularly where Plaintiff was represented by counsel.
2. The court held that substantial evidence supported the ALJ's residual functional capacity finding and conclusion that Plaintiff was not disabled during any continuous twelve-month period between July 2021 and January 2024.

Questions Presented

1. Whether substantial evidence supported the ALJ's residual functional capacity determination and finding that Plaintiff was not disabled during the relevant period.
2. Whether the ALJ was required to consider a closed period of disability when Plaintiff had not presented that theory to the ALJ.

Disposition

affirmed