Susan C. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Washington affirmed the Administrative Law Judge’s denial of Susan C.’s applications for disability insurance benefits and supplemental security income. The court held that the ALJ adequately evaluated her subjective symptom complaints concerning her knee impairments, migraines, and mental impairments, and entered judgment for the Commissioner.

Holdings

1. The ALJ properly evaluated Plaintiff's subjective complaints because the ALJ identified specific evidence inconsistent with the alleged severity of her limitations, including her public-facing jewelry business, relatively manageable knee findings, and improvement in migraines with Botox and Nurtec. The ALJ's reasons were supported by substantial evidence and any claimed error was not consequential.
2. Plaintiff's challenge to the ALJ's step-five finding was moot because the ALJ independently found at step four that Plaintiff could perform her past relevant work.

Questions Presented

1. Whether the ALJ provided legally sufficient, specific, clear, and convincing reasons supported by substantial evidence for discounting Plaintiff's subjective symptom reports concerning her knee impairments, migraines, and mental impairments.
2. Whether Plaintiff's challenge to the ALJ's step-five finding warranted relief.

Disposition

affirmed