Mark Johnson v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California reviews a Social Security disability benefits determination following a prior remand from the Court of Appeals. The court concludes that substantial evidence supports the ALJ’s findings regarding the paragraph C.2 criteria, residual functional capacity, medical opinions, plaintiff’s testimony, and third-party evidence. Plaintiff’s motion for summary judgment is denied, and the Commissioner’s motion for summary judgment is granted.

Holdings

1. The ALJ's finding that Johnson did not establish marginal adjustment under paragraph C.2 was supported by substantial evidence. Evidence that Johnson attended Alcoholics Anonymous meetings, traveled, managed insurance changes, pursued activities such as joining a gym, and adapted to treatment and medication changes reasonably supported a finding of greater-than-marginal adjustment without the required exacerbation of symptoms or deterioration in functioning.
2. The RFC determination was supported by substantial evidence, and the ALJ reasonably evaluated the medical opinions using the supportability and consistency factors. The ALJ permissibly found the opinions of Drs. Brode and Zukowsky persuasive, partially credited Dr. Giannuli's opinion, and found the opinions of Paoli, Dr. Smith, and Anglim less persuasive.
3. The ALJ provided specific, clear, and convincing reasons for discounting Johnson's testimony concerning the severity of his memory, concentration, and interpersonal limitations.
4. The ALJ provided a germane and reasonable basis for partially discounting Kelli Hoppe's third-party function report, relying on conflicts between her broad descriptions and clinical findings, Johnson's reported activities, and examination observations.

Questions Presented

1. Whether substantial evidence supported the ALJ's finding that Johnson did not satisfy paragraph C.2 of Listings 12.04, 12.06, or 12.15.
2. Whether substantial evidence supported the ALJ's residual functional capacity determination and evaluation of medical opinions.
3. Whether the ALJ gave legally sufficient reasons for discounting Johnson's subjective symptom testimony.
4. Whether the ALJ provided a sufficient basis for partially discounting third-party evidence from Kelli Hoppe.

Disposition

other