Elizabeth Ann Debilzen v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania affirmed the Commissioner of Social Security’s denial of Elizabeth Ann Debilzen’s claim for supplemental security income. The court held that the administrative law judge’s evaluation of medical opinion evidence, activities of daily living, and residual functional capacity was supported by substantial evidence.

Holdings

1. The ALJ adequately explained why Dr. Campbell's opinion was unpersuasive, and the residual functional capacity determination was supported by substantial evidence.
2. The ALJ reasonably considered Debilzen's activities of daily living, and those activities, considered together with the medical evidence, supported the RFC and the finding of only mild mental limitations.
3. The Commissioner's decision denying benefits was supported by substantial evidence and was affirmed.

Questions Presented

1. Whether the ALJ's evaluation of Dr. Campbell's mental-health medical opinion and resulting residual functional capacity were supported by substantial evidence.
2. Whether the ALJ improperly relied on Debilzen's activities of daily living when assessing the severity of her mental impairments and residual functional capacity.
3. Whether the Commissioner's denial of benefits was supported by substantial evidence and based on a correct application of law.

Disposition

affirmed