Summary
The United States District Court for the Middle District of Pennsylvania reviews Gregory Joseph Neifert’s third appeal from the denial of Social Security disability insurance benefits for a closed period following a traumatic brain injury. The court concludes that substantial evidence supports the Administrative Law Judge’s residual functional capacity assessment and recommends affirming the Commissioner’s decision. The opinion discusses Neifert’s medical history, activities of daily living, employment, and the weight assigned to medical opinions.
Holdings
- The ALJ's decision denying Neifert's closed-period disability claim was supported by substantial evidence and was reached through a correct application of law.
- An ALJ is not required to base the residual functional capacity assessment on a medical opinion that mirrors the assessment or contains the particular findings adopted by the ALJ.
- The ALJ properly afforded little weight to Dr. John's opinion that Neifert was completely disabled because the opinion conflicted with objective examination findings, the longitudinal record, and Neifert's demonstrated ability to work and manage daily activities.
Questions Presented
- Whether substantial evidence supported the ALJ's residual functional capacity assessment despite the absence of a medical opinion mirroring every limitation adopted by the ALJ.
- Whether the ALJ properly discounted the 2021 opinion of treating source Dr. Denny John that Neifert was completely disabled during the earlier disability period.
- Whether substantial evidence supported the ALJ's finding that Neifert had no exertional limitations and could perform work at all exertional levels.
- Whether the ALJ adequately articulated the reasons for evaluating the medical opinions, subjective allegations, and other evidence.
Disposition
affirmed
Cases Cited (42)
- T-Mobile South, LLC v. Roswell, 574 U.S. ___, 135 S. Ct. 808, 815, 190 L. Ed. 2d 679 (2015)(cited)
- Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S. Ct. 206, 83 L. Ed. 126 (1938)(cited)
- Perales, 402 U.S. at 401, 91 S. Ct. 1420(cited)
- Dickinson v. Zurko, 527 U.S. 150, 153, 119 S. Ct. 1816, 144 L. Ed. 2d 143 (1999)(cited)
- Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019)(cited)
- Johnson v. Comm'r of Soc. Sec., 529 F.3d 198, 200 (3d Cir. 2008)(cited)
- Ficca v. Astrue, 901 F. Supp. 2d 533, 536 (M.D. Pa. 2012)(cited)
- Pierce v. Underwood, 487 U.S. 552, 565 (1988)(cited)
- Richardson v. Perales, 402 U.S. 389, 401 (1971)(cited)
- Mason v. Shalala, 994 F.2d 1058, 1064 (3d Cir. 1993)(cited)
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Cited In (0)
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Court Document
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