Nicki Jackson v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Alabama overruled Nicki Jackson’s objections to a magistrate judge’s recommendation in a Social Security disability benefits case. The court adopted the recommendation, denied the plaintiff’s motion for summary judgment, granted the Commissioner’s motion for summary judgment, and affirmed the denial of benefits.

Holdings

1. The ALJ did not commit reversible error by failing to specifically cite Plaintiff's hearing testimony because an ALJ need not examine every piece of evidence or cite particular phrases or formulations when the decision demonstrates consideration of the claimant's medical condition as a whole.
2. The ALJ was not required to treat symptoms allegedly caused by endometriosis as affecting Plaintiff's ability to work where the record contained no evidence that endometriosis was a medically determinable impairment.
3. Substantial evidence supported the ALJ's residual functional capacity determination and the Commissioner's denial of benefits.

Questions Presented

1. Whether the ALJ committed reversible error by failing to specifically reference Plaintiff's hearing testimony when evaluating her subjective symptoms.
2. Whether any failure by the ALJ to reference Plaintiff's hearing testimony was harmless.
3. Whether substantial evidence supported the ALJ's residual functional capacity determination and the Commissioner's denial of benefits.

Disposition

affirmed