Christina Kang v. Commissioner of Social Security

Summary

The United States District Court for the Middle District of Florida reviewed the Commissioner of Social Security’s denial of Christina Kang’s applications for disability insurance benefits and supplemental security income. The court held that substantial evidence supported the administrative law judge’s decision, including the evaluation of fibromyalgia and Kang’s subjective statements about her limitations, and affirmed the Commissioner’s decision.

Holdings

1. The ALJ's failure to mention fibromyalgia did not require remand because Kang did not identify record evidence showing that fibromyalgia caused work-related limitations or satisfied the criteria for a medically determinable impairment, and the ALJ otherwise considered the relevant limitations throughout the sequential evaluation.
2. The ALJ properly evaluated Kang's subjective statements and clearly articulated explicit and adequate reasons for finding that the alleged intensity, persistence, and limiting effects of her symptoms were not entirely consistent with the medical and other evidence.

Questions Presented

1. Whether the ALJ committed reversible error by failing to expressly discuss Kang's documented fibromyalgia at each step of the sequential evaluation.
2. Whether the ALJ properly evaluated Kang's subjective statements concerning the limiting effects of her pain and other symptoms.

Disposition

affirmed