John Lampshire v. Commissioner of Social Security

Summary

The document contains findings and recommendations in John Lampshire’s action for judicial review of a Social Security disability determination under 42 U.S.C. § 405(g). The court evaluates challenges to the ALJ’s treatment of medical opinions and recommends affirming the Commissioner’s decision, concluding that the ALJ’s residual functional capacity assessment was consistent with the medical evidence and that the treatment of the opinions was adequately explained.

Holdings

1. The ALJ did not reversibly err by finding Dr. Allen’s opinions persuasive and adopting a limited-light-work residual functional capacity. Although Dr. Allen used the term sedentary in one report, the specific limitations he assessed were consistent with light work involving sitting most of the day and unrestricted upper- and lower-extremity manipulation.
2. The ALJ properly discounted Dr. Addagatta’s 2023 opinion because it was outside the relevant period, was more restrictive than Dr. Allen’s opinions, and was less consistent with the record as a whole.
3. The Commissioner’s final decision should be affirmed because the ALJ applied proper legal standards and the challenged findings were supported by substantial evidence.

Questions Presented

1. Whether the ALJ improperly evaluated Dr. J. Allen’s medical opinions by finding them persuasive while adopting a residual functional capacity for limited light work despite Dr. Allen’s statement that the claimant was capable of sedentary work.
2. Whether the ALJ improperly discounted Dr. Jane Addagatta’s opinion because it was prepared after the claimant’s date last insured.
3. Whether the ALJ’s evaluation of the medical opinions was supported by substantial evidence and adequate reasoning under the revised medical-opinion regulations.

Disposition

affirmed