J.G. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Pennsylvania reviews the Commissioner of Social Security’s denial of the plaintiff’s applications for disability insurance benefits and supplemental security income. The court holds that the administrative law judge’s decision is supported by substantial evidence, including the assessment of the plaintiff’s mental impairments and limitations in interacting with others, and affirms the Commissioner’s decision.

Holdings

1. The ALJ's decision that Plaintiff was not disabled during the closed period was supported by substantial evidence.
2. The ALJ's failure to state clearly in the written RFC whether Plaintiff had no, mild, or moderate social-interaction limitations was harmless because the vocational expert testified that the same jobs remained available even with no public interaction and only occasional interaction with coworkers and supervisors.
3. The ALJ properly declined to give controlling weight to Dr. Mueller's opinion and reasonably assigned it little weight.

Questions Presented

1. Whether substantial evidence supported the Commissioner's determination that Plaintiff was not disabled during the closed period.
2. Whether the ALJ adequately accounted for Plaintiff's alleged limitations in interacting with others in the residual functional capacity assessment.
3. Whether the ALJ properly discounted the treating-source opinion of Dr. Mueller.
4. Whether any omission of social-interaction restrictions from the written RFC was harmless in light of the vocational expert's testimony.

Disposition

affirmed