Melissa H. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Washington affirmed the Commissioner of Social Security's decision denying Melissa H.'s applications for Disability Insurance Benefits and Supplemental Security Income. The court held that the Administrative Law Judge's evaluation of her subjective statements and residual functional capacity was supported by substantial evidence and free of legal error.

Holdings

1. The ALJ properly rejected aspects of the plaintiff's subjective symptom testimony because, absent evidence of malingering, the ALJ gave specific, clear, and convincing reasons supported by the medical record, the plaintiff's statements to providers, consultative examinations, and daily activities.
2. The RFC was not required to include limitations arising solely from symptom testimony that the ALJ reasonably rejected.
3. The ALJ's decision denying benefits was supported by substantial evidence and was not based on legal error.

Questions Presented

1. Whether substantial evidence and proper legal standards supported the ALJ's evaluation of the plaintiff's subjective symptom testimony.
2. Whether the ALJ's residual functional capacity assessment was required to include additional limitations based on the plaintiff's testimony concerning standing, walking, lying down to control pain, and lifting.

Disposition

affirmed