Latasha Nicole Morgan 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 Latasha Nicole Morgan’s application for supplemental security income. The court held that the evidence concerning available jobs was sufficient to support the step-five determination and that the ALJ provided adequate reasons for discounting Morgan’s symptom testimony. Plaintiff’s motion for summary judgment was denied, the Commissioner’s cross-motion was granted, and the decision was affirmed.

Holdings

1. The evidence estimating 21,215 jobs in the national economy did not require remand because that number constitutes a significant number of jobs, and any discrepancy between the vocational expert's estimate and the later evidence was harmless.
2. The ALJ provided specific, clear, and convincing reasons supported by substantial evidence for discounting the more severe aspects of Morgan's subjective symptom testimony.

Questions Presented

1. Whether the evidence submitted to the Appeals Council concerning the number of jobs available in the national economy undermined the ALJ's step-five finding.
2. Whether the ALJ gave legally sufficient specific, clear, and convincing reasons for discounting the more severe aspects of Morgan's subjective symptom testimony.

Disposition

affirmed