David M. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Pennsylvania reviewed the denial of David M.’s claims for Disability Insurance Benefits and Supplemental Security Income. The court held that substantial evidence supported the Administrative Law Judge’s evaluation of the medical evidence, subjective complaints, residual functional capacity, and vocational evidence, and affirmed the Commissioner’s decision.

Holdings

1. The ALJ properly discounted David M.'s subjective complaints to the extent they were inconsistent with the medical and other evidence, and substantial evidence supported the resulting symptom findings.
2. Substantial evidence supported the ALJ's finding that David M. could perform modified light work and could perform the identified jobs of clerical checker, office helper, and information clerk in significant numbers.
3. The ALJ adequately evaluated Dr. Monfared's opinion under the post-March 27, 2017 regulations by considering its supportability and consistency and assigning it only partial persuasiveness.
4. The ALJ adequately considered obesity individually and in combination with David M.'s other impairments, and any alleged deficiency was harmless because the claimant identified no additional functional limitation that should have been included in the RFC.

Questions Presented

1. Whether substantial evidence supported the ALJ's evaluation of David M.'s subjective complaints and symptom limitations.
2. Whether substantial evidence supported the ALJ's residual functional capacity finding and step-five conclusion that David M. could perform other work in the national economy.
3. Whether the ALJ properly evaluated the medical opinion of Dr. Ziba Monfared.
4. Whether the ALJ adequately considered the combined effects of David M.'s obesity and other impairments.

Disposition

affirmed