Clint Jervis v. Frank Bisignano, Commissioner of Social Security

Summary

The court reviewed the denial of Clint Jervis's claim for Supplemental Security Income under the substantial-evidence and correct-legal-standards framework. It rejected challenges to the ALJ's RFC limitation to simple work, the ALJ's discussion of the evidence, and the alleged failure to develop the record. The court affirmed the Commissioner's decision and directed the Clerk to enter final judgment and close the case.

Holdings

1. The ALJ's limitation of Plaintiff to simple, unskilled work adequately accounted for his moderate limitations in understanding, remembering, or applying information and in concentrating, persisting, or maintaining pace.
2. The ALJ's discussion of the evidence was sufficient because the decision as a whole explained the basis for the RFC determination and was supported by substantial evidence; the ALJ was not required to discuss every piece of evidence individually.
3. The ALJ did not violate the duty to develop the record by failing to obtain a mental-health opinion or consultative mental-status examination.

Questions Presented

1. Whether the ALJ's RFC limitation to simple work was impermissibly vague or failed to account for Plaintiff's moderate limitations in understanding, remembering, or applying information and in concentrating, persisting, or maintaining pace.
2. Whether the ALJ's discussion of the evidence was inadequate to permit meaningful judicial review or improperly relied on selectively chosen evidence.
3. Whether the ALJ failed to develop the record by not obtaining a mental-health opinion or consultative mental-status examination.

Disposition

affirmed