Crystal M. v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of North Carolina reviews the Commissioner of Social Security’s denial of Crystal M.’s application for Supplemental Security Income. The court analyzes the administrative law judge’s evaluation of Plaintiff’s subjective complaints of pain, including the medical evidence, treatment history, and residual functional capacity assessment. The court concludes that Plaintiff has not established entitlement to relief and enters judgment for the Commissioner.

Holdings

1. The ALJ properly applied the two-part regulatory framework by finding that Plaintiff's medically determinable impairments could reasonably be expected to produce some symptoms and then evaluating the intensity, persistence, and limiting effects of those symptoms in light of the entire record.
2. The ALJ did not violate Arakas or Oakes by considering objective medical evidence in evaluating pain arising from a healed femur fracture and chronic pain syndrome.
3. The ALJ permissibly considered Plaintiff's generally stable pain-treatment history and relatively unchanged opioid medication in assessing the intensity, persistence, and limiting effects of her symptoms.
4. The ALJ's failure to expressly discuss sitting, standing, and walking on a separate function-by-function basis did not require remand because the decision provided an accurate and logical bridge between the evidence and the RFC finding.

Questions Presented

1. Whether the ALJ applied the correct legal standard in evaluating Plaintiff's subjective complaints of pain.
2. Whether the ALJ improperly relied on objective medical findings to discount Plaintiff's subjective symptom reports.
3. Whether the ALJ improperly relied on Plaintiff's stable pain-treatment history.
4. Whether the ALJ failed to perform an adequate function-by-function residual-functional-capacity assessment, particularly concerning sitting, standing, walking, and the frequency of position changes.

Disposition

affirmed