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

Summary

The United States District Court for the Eastern District of Virginia 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 properly evaluated the plaintiff’s physical and mental impairments, residual functional capacity, and medical opinion evidence, including alleged off-task time and absenteeism. The court denies the plaintiff’s motion, grants the Commissioner’s motion, and affirms the Commissioner’s decision.

Holdings

1. The ALJ reasonably accounted for Plaintiff's supported physical and mental limitations in an RFC restricting her to a reduced range of light work, and substantial evidence did not require additional limitations for off-task time, unscheduled breaks, or absenteeism.
2. The ALJ properly evaluated Dr. Scott's opinion by addressing its supportability and consistency and reasonably found it unpersuasive.
3. Because the RFC determination was not erroneous, the vocational-expert hypotheticals were not legally insufficient for omitting unsupported additional limitations.

Questions Presented

1. Whether the ALJ's residual functional capacity determination was supported by substantial evidence despite not including additional limitations for off-task time, unscheduled breaks, or absenteeism.
2. Whether the ALJ properly evaluated the persuasiveness of psychiatrist Randall Scott's medical opinion under 20 C.F.R. §§ 404.1520c and 416.920c.
3. Whether the vocational-expert hypotheticals were legally insufficient because they omitted alleged additional RFC limitations.

Disposition

affirmed