Jordan Denae Keever v. Frank J. Bisignano

Summary

The United States District Court for the Eastern District of Oklahoma affirmed the Commissioner of Social Security’s denial of Jordan Denae Keever’s applications for disability insurance benefits and supplemental security income. The court held that the ALJ properly evaluated Keever’s subjective symptoms, chronic pain syndrome, physical residual functional capacity, and non-severe mental impairments, and that the decision was supported by substantial evidence and applied the correct legal standards.

Holdings

1. The ALJ properly evaluated Keever's subjective symptoms because the ALJ considered the applicable factors, explained why the alleged severity of the symptoms was inconsistent with the treatment record, and linked the findings to substantial evidence.
2. The ALJ's failure to expressly classify or discuss chronic pain syndrome at step two was harmless because the ALJ found other severe impairments and proceeded through the sequential evaluation, thereby becoming obligated to consider all of Keever's impairments in the later residual functional capacity assessment.
3. The ALJ's physical residual functional capacity assessment was supported by substantial evidence even though the ALJ found the state-agency physicians' opinions unpersuasive.
4. The ALJ did not err by omitting mental restrictions from the RFC and vocational-expert hypothetical because mild limitations in the paragraph B criteria do not necessarily establish work-related functional limitations, and the ALJ adopted supported opinions finding no functional mental limitations.

Questions Presented

1. Whether the ALJ improperly evaluated Keever's subjective statements concerning the intensity, persistence, and limiting effects of her symptoms.
2. Whether the ALJ erred by failing to classify or expressly address chronic pain syndrome at step two and by failing to account for it in the residual functional capacity assessment.
3. Whether the ALJ's physical residual functional capacity assessment was unsupported because the ALJ found the state-agency medical opinions unpersuasive.
4. Whether the ALJ erred by omitting mental limitations from the residual functional capacity assessment and the hypothetical question to the vocational expert despite finding mild limitations in interacting with others and concentrating, persisting, or maintaining pace.

Disposition

affirmed