Jose N. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Washington denied Plaintiff Jose N.'s motion for summary judgment and affirmed the Commissioner of Social Security's denial of his Title II disability benefits application. The court reviewed the ALJ's evaluation of medical evidence, residual functional capacity, alleged malingering, mental impairments, and step-five findings.

Holdings

1. The ALJ properly evaluated the medical evidence and Plaintiff's subjective symptom allegations, and the RFC determination was supported by substantial evidence.
2. The ALJ did not err in finding affirmative evidence of malingering; therefore, the ALJ was not required to provide clear and convincing reasons for rejecting Plaintiff's subjective symptom testimony.
3. The ALJ's failure to separately identify or discuss the somatic symptom disorder diagnosis did not establish harmful error because a diagnosis alone does not establish a medically determinable impairment or functional limitations.
4. The ALJ did not commit reversible error at step five, and the Commissioner met the burden of showing that Plaintiff could perform jobs existing in significant numbers in the national economy.

Questions Presented

1. Whether the ALJ properly evaluated the medical evidence and Plaintiff's alleged symptoms in determining his residual functional capacity.
2. Whether the ALJ erred by failing to account for alleged somatic symptom disorder and moderate mental limitations in the residual functional capacity.
3. Whether the ALJ properly found affirmative evidence of malingering and therefore applied the appropriate standard when evaluating Plaintiff's subjective symptom testimony.
4. Whether the Commissioner met the step-five burden by relying on vocational-expert testimony based on the ALJ's residual functional capacity assessment.

Disposition

affirmed