Burks v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California reviews a final decision denying Supplemental Security Income benefits on behalf of a minor claimant with a learning disability and ADHD. The court applies the substantial-evidence standard and affirms the Commissioner’s decision, concluding that the ALJ adequately evaluated the claimant’s functional limitations and the medical opinion evidence.

Holdings

1. The ALJ adequately evaluated Dr. Savage's opinion under the revised regulations by explaining that the opinion was unpersuasive because it was inconsistent with the objective medical, educational, and other evidence in the record.
2. The ALJ did not err in discounting the special education teacher's statements because the ALJ expressly considered them and provided reasons tied to the record for finding that they overstated the claimant's limitations.
3. Substantial evidence and proper legal analysis supported the Commissioner's conclusion that the claimant was not disabled.

Questions Presented

1. Whether the ALJ properly evaluated the medical opinion of treating psychologist Dr. Savage under the revised Social Security regulations.
2. Whether the ALJ properly evaluated evidence from the claimant's special education teacher concerning the claimant's limitations in attending and completing tasks.
3. Whether substantial evidence supported the ALJ's finding that the claimant had less-than-marked limitations in acquiring and using information and attending and completing tasks.

Disposition

affirmed