Stacey Savy Meas v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California denied Stacey Savy Meas’s motion for summary judgment and granted the Commissioner of Social Security’s cross-motion. The court upheld the administrative finding that Meas’s disability ended on October 21, 2021, concluding that substantial evidence supported the findings regarding medical improvement, subjective symptoms, residual functional capacity, and available work. The Clerk was directed to enter judgment for the Commissioner.

Holdings

1. The ALJ reasonably found medical improvement because plaintiff no longer had the cervical-cancer impairment that had met the applicable listing at the comparison point decision, and the record showed that the cancer had been successfully treated without evidence of disease or recurrence.
2. The ALJ properly evaluated plaintiff's subjective symptom testimony because, absent evidence of malingering, the ALJ identified specific, clear, and convincing reasons supported by the record for finding that the alleged intensity, persistence, and limiting effects of the symptoms were not entirely consistent with the evidence.
3. The ALJ's residual functional capacity determination was supported by substantial evidence, and plaintiff did not demonstrate that the RFC failed to account for her alleged pain, need for an assistive device, memory problems, or pace limitations.
4. The ALJ did not err at step five because the step-five challenge depended on the alleged defects in the RFC determination, and those alleged defects were not established.

Questions Presented

1. Whether the ALJ reasonably found that plaintiff experienced medical improvement as of October 21, 2021.
2. Whether the ALJ properly evaluated and discounted plaintiff's subjective symptom testimony.
3. Whether the ALJ's residual functional capacity determination was supported by substantial evidence.
4. Whether the ALJ erred at step five by finding that plaintiff could perform jobs available in the national economy.

Disposition

other