Steven P. v. Frank Bisignano

Summary

The United States District Court for the Eastern District of Virginia reviews the denial of Steven P.'s application for Social Security disability insurance benefits. The court concludes that the Administrative Law Judge applied the correct legal standards, properly evaluated the claimant's subjective complaints and medical opinion evidence, and supported the residual functional capacity determination with substantial evidence. The court denies the claimant's motions, grants the Commissioner's motion for summary judgment, and affirms the Commissioner's final decision.

Holdings

1. The ALJ applied the required two-step process for evaluating subjective symptoms, reasonably explained the inconsistencies between Plaintiff's allegations and the record, and supported the RFC determination with substantial evidence.
2. Substantial evidence supported the ALJ's finding that Plaintiff could perform light work with limitations on sitting, standing, postural activities, left-arm reaching and pushing or pulling, handling, environmental exposure, and workplace hazards.
3. The ALJ properly evaluated the medical opinions and prior administrative findings by addressing their supportability and consistency and reasonably found certain opinions unpersuasive.
4. Because the RFC determination was supported by substantial evidence, the vocational-expert hypotheticals did not contain reversible error.

Questions Presented

1. Whether the ALJ properly evaluated Plaintiff's subjective complaints and whether substantial evidence supported the resulting residual functional capacity determination.
2. Whether the ALJ properly evaluated the medical opinions and prior administrative medical findings under 20 C.F.R. § 404.1520c.
3. Whether the ALJ's residual functional capacity findings required different vocational-expert hypotheticals or a finding that Plaintiff was limited to sedentary work.

Disposition

affirmed