Vincent Bernard Davis v. Commissioner of Social Security

Summary

The Eastern District of California upheld the Commissioner of Social Security’s determination that Vincent Bernard Davis’s disability ended on March 1, 2020. The court rejected challenges concerning the ALJ’s treatment of psychological consultant opinions and the evaluation of Davis’s subjective symptom testimony. Plaintiff’s motion for summary judgment was denied, the Commissioner’s cross-motion was granted, and judgment was ordered for the Commissioner.

Holdings

1. The ALJ did not commit reversible error by adopting most of Dr. Colsky's opinion and translating the narrative limitations into the residual functional capacity. Although the ALJ should have expressly adopted or rejected the moderate limitation concerning completing a normal workday and workweek without interruption, the opinion as a whole rationally supported the ALJ's conclusion that plaintiff could perform simple, repetitive work with limited public interaction and other restrictions.
2. The ALJ provided legally sufficient specific, clear, and convincing reasons for discounting plaintiff's testimony concerning the intensity, persistence, and limiting effects of his symptoms.

Questions Presented

1. Whether the ALJ properly evaluated and incorporated the moderate limitations identified by psychological consultant Dr. L. Colsky, particularly the limitation concerning completing a normal workday or workweek without interruption from psychological symptoms.
2. Whether the ALJ provided legally sufficient, specific, clear, and convincing reasons for discounting plaintiff's subjective symptom testimony.

Disposition

affirmed