Angela Lee v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California reviewed the denial of Angela Lee’s application for Social Security disability benefits. The court held that the Administrative Law Judge provided sufficient reasons for evaluating Lee’s subjective symptom testimony and properly evaluated the medical opinion of Dr. Faurbo, and therefore upheld the Commissioner’s decision.

Holdings

1. The ALJ properly discounted Plaintiff's testimony concerning the extent of her limitations because the ALJ identified clear and convincing reasons, including Plaintiff's daily activities and improvement with treatment, that were supported by substantial evidence.
2. The ALJ erred by failing to link the normal mental-health and cognitive findings to specific portions of Plaintiff's testimony, but the error was harmless.
3. The ALJ properly evaluated Dr. Faurbo's opinion under the revised Social Security regulations because the ALJ addressed its supportability and consistency and supported the conclusion with substantial evidence.

Questions Presented

1. Whether the ALJ provided legally sufficient reasons supported by substantial evidence for discounting Plaintiff's testimony concerning the intensity, persistence, and limiting effects of her symptoms.
2. Whether the ALJ properly evaluated and discounted Dr. Faurbo's medical opinion under 20 C.F.R. § 404.1520c.
3. Whether any error in the ALJ's failure to link normal mental-health and cognitive findings to specific portions of Plaintiff's testimony was harmful.

Disposition

affirmed