D.S.A. v. Commissioner of Social Security

Summary

The United States District Court for the Middle District of Georgia reviews the Commissioner of Social Security’s denial of D.S.A.’s application for disability insurance benefits under 42 U.S.C. § 405(g). The court rejects challenges concerning the formulation of the residual functional capacity, consideration of traumatic brain injury, and alleged mental-health limitations. The Commissioner’s decision is affirmed.

Holdings

1. The ALJ was not required to obtain medical-opinion testimony or a consultative examination before assessing Plaintiff's residual functional capacity. The ALJ properly evaluated the record evidence and performed the adjudicator's regulatory role in determining RFC.
2. The ALJ did not commit reversible error by failing to use the specific words 'traumatic brain injury.' The ALJ adequately considered the impairments allegedly resulting from that injury, including seizures and headaches.
3. The ALJ's finding that Plaintiff's adjustment disorder with anxiety, PTSD, and depression were non-severe was supported by substantial evidence.
4. The ALJ did not err by including no specific mental limitations in the RFC. The decision, read as a whole, adequately considered Plaintiff's mental impairments and explained why no additional mental restrictions were warranted.

Questions Presented

1. Whether the ALJ erred by assessing Plaintiff's residual functional capacity without a medical-source opinion or consultative examination.
2. Whether the ALJ failed to consider Plaintiff's traumatic brain injury.
3. Whether the ALJ erred in finding Plaintiff's mental impairments non-severe.
4. Whether the ALJ failed to account for mental limitations in the residual functional capacity assessment.

Disposition

affirmed