Felicia Brunner v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania reviews Felicia Brunner’s challenge to the denial of Title II Social Security disability benefits. The court holds that substantial evidence supports the Administrative Law Judge’s residual functional capacity assessment and finding that Brunner could perform her past relevant work as generally performed in the national economy. The court therefore affirms the Commissioner’s decision denying benefits.

Holdings

1. The ALJ's finding that Brunner was not disabled was supported by substantial evidence and was based on a correct application of law.
2. The ALJ was not required to make a transferability-of-skills finding because the ALJ determined at Step 4 that Brunner could perform her past relevant work as generally performed.
3. The ALJ was not required to accept the vocational-expert testimony that no jobs would be available under a hypothetical incorporating frequent breaks and absences because those limitations were based on subjective allegations the ALJ reasonably found unsupported.

Questions Presented

1. Whether substantial evidence supported the ALJ's residual-functional-capacity determination and finding that Brunner could perform her past relevant work as generally performed.
2. Whether the ALJ was required to determine the transferability of Brunner's work skills because she was closely approaching retirement age and limited to light work.
3. Whether the ALJ was required to accept a vocational-expert hypothetical incorporating frequent breaks and absences based on Brunner's subjective testimony.

Disposition

affirmed