Elizabeth Nicole Marshall v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania reviews Elizabeth Nicole Marshall’s appeal from the denial of her application for Social Security disability insurance benefits. The court concludes that the Administrative Law Judge’s findings and residual functional capacity determination are supported by substantial evidence and affirms the Commissioner’s decision.

Holdings

1. The ALJ's finding that Marshall's physical impairments were non-severe was supported by substantial evidence and did not require a remand.
2. The mere existence of substantial medical evidence submitted after the state-agency consultants' reviews did not establish that reliance on their opinions was improper or require remand.
3. The ALJ adequately explained why the opinions of Dr. Corum and Jacob Sterner were unpersuasive, and the evaluation of the medical opinions was supported by substantial evidence.
4. The ALJ's evaluation of Marshall's alleged symptoms was supported by substantial evidence and adequately explained.

Questions Presented

1. Whether substantial evidence supported the ALJ's finding at step two that Marshall's physical impairments were non-severe.
2. Whether the ALJ properly evaluated the state-agency medical and psychological opinions despite receiving additional medical evidence after the consultants' reviews.
3. Whether the ALJ adequately explained the decision to find the opinions of Dr. Corum and Jacob Sterner, PT, unpersuasive.
4. Whether the ALJ's evaluation of Marshall's subjective symptoms was supported by substantial evidence and adequately articulated.

Disposition

affirmed