Christopher B. v. Frank J. Bisignano, Commissioner of Social Security Administration

Summary

The United States District Court for the Eastern District of Missouri reviewed an Administrative Law Judge’s denial of Christopher B.’s application for Social Security disability insurance benefits. The court held that the ALJ’s assessment of medical opinions and residual functional capacity, including limitations on handling, fingering, and feeling, was supported by substantial evidence. The court affirmed the Commissioner’s decision.

Holdings

1. The ALJ properly evaluated the persuasiveness of the opinions of Drs. McGraw and Sandvos by addressing their supportability and consistency, as required by 20 C.F.R. § 404.1520c.
2. The ALJ's finding that Plaintiff could perform sedentary work with frequent handling, fingering, and feeling was supported by substantial evidence.
3. The ALJ's mistaken statement that both Dr. McGraw and Dr. Sandvos found manipulative limitations was harmless error.
4. The Commissioner's decision must be affirmed when the ALJ's findings are supported by substantial evidence on the record as a whole and fall within the permissible zone of choice.

Questions Presented

1. Whether the ALJ properly evaluated the supportability and consistency of the medical opinions of Drs. Dennis McGraw and Charity Sandvos.
2. Whether the ALJ's residual functional capacity finding, including the limitation to frequent handling, fingering, and feeling, was supported by substantial evidence.
3. Whether the ALJ's erroneous statement that both agency examiners found manipulative limitations required remand.

Disposition

affirmed