Sandy Valdez v. Frank Bisignano, Commissioner of Social Security

Summary

The court adopted the magistrate judge’s findings and recommendations in a Social Security disability case. It denied Sandy Valdez’s motion for summary judgment, granted the Commissioner’s request to affirm the administrative decision, and entered judgment for the defendant. The court concluded that the ALJ adequately evaluated Valdez’s residual functional capacity, subjective symptom testimony, obesity, and nonsevere impairments.

Holdings

1. The ALJ provided sufficiently specific clear and convincing reasons for discounting Valdez's subjective symptom testimony by identifying testimony concerning disabling pain and linking it to medical evidence showing significant improvement after back surgery and favorable results from knee arthroplasty.
2. Daily activities may support an adverse credibility determination on either of two independent grounds: the activities contradict the claimant's testimony, or the activities meet the threshold for transferable work skills. When the ALJ relies on contradiction, a separate finding of transferability is not required.
3. Any error in omitting the environmental limitations from the vocational-expert hypotheticals was harmless because the Dictionary of Occupational Titles listing for accounting clerk did not include exposure to the environmental conditions identified in Valdez's residual functional capacity.
4. The ALJ did not err in evaluating obesity or in finding Valdez's right hip pain, upper-extremity numbness, depression, and anxiety nonsevere where the ALJ considered the impairments, applied the applicable mental-impairment criteria, accounted for obesity and musculoskeletal impairments in limiting Valdez to a reduced range of sedentary work, and the record supported the findings.

Questions Presented

1. Whether the ALJ erred by relying on vocational evidence despite environmental limitations in the residual functional capacity not being included in the vocational-expert hypotheticals.
2. Whether the ALJ provided legally sufficient reasons for discounting Valdez's subjective symptom testimony.
3. Whether the ALJ improperly relied on Valdez's daily activities without finding that the activities were transferable to a work setting.
4. Whether the ALJ properly evaluated Valdez's obesity and incorporated its effects into the residual functional capacity.
5. Whether the ALJ properly evaluated Valdez's nonsevere impairments at step two.

Disposition

other