Lasharee Devona Williams v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California reviewed the Commissioner of Social Security’s denial of Lasharee Devona Williams’s applications for supplemental security income and disability insurance benefits. The court denied Plaintiff’s motion for summary judgment, granted the Commissioner’s motion for summary judgment, and affirmed the Commissioner’s decision, concluding that the ALJ’s RFC assessment and evaluation of the medical opinions, symptom claims, and lay witness evidence were supported by substantial evidence.

Holdings

1. The ALJ properly evaluated Carmen Sorisho's medical opinion under the revised Social Security regulations and reasonably formulated an RFC limiting Williams to light work with simple instructions, supervisor instructions, and restricted coworker and public interactions.
2. The ALJ provided clear and convincing, substantial-evidence-supported reasons for discounting Williams's subjective symptom claims.
3. The ALJ did not err by considering but not separately explaining the treatment of the lay witness report because the applicable regulations do not require articulation of how evidence from nonmedical sources was considered.

Questions Presented

1. Whether the ALJ's residual functional capacity determination was supported by substantial evidence, including the evaluation of medical opinion evidence.
2. Whether the ALJ properly evaluated Williams's subjective symptom claims.
3. Whether the ALJ properly considered the lay witness evidence.

Disposition

affirmed