Ryan Copertino v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania reviews Ryan Copertino’s appeal from the denial of his applications for Social Security disability insurance benefits and supplemental security income. The court concludes that the Administrative Law Judge’s residual functional capacity assessment, evaluation of the medical opinions and subjective symptoms, and determination at step five are supported by substantial evidence. The court therefore affirms the Commissioner’s decision denying benefits.

Holdings

1. The ALJ adequately addressed the limitation by restricting Copertino to carrying out simple instructions, even though the RFC did not use the exact phrase "one-to-two-step tasks."
2. Any error concerning the relationship between the simple-instructions limitation and the reasoning-level-two occupations was harmless because the vocational expert identified a reasoning-level-one night-cleaner occupation that the claimant could perform.
3. The ALJ's evaluation of Copertino's subjective symptoms was supported by substantial evidence and adequately explained.
4. The ALJ's decision denying Copertino's applications for benefits was supported by substantial evidence and resulted from application of the correct legal standards.

Questions Presented

1. Whether the ALJ's RFC limitation to simple instructions adequately addressed the opinion that Copertino could perform one- and two-step tasks.
2. Whether any inconsistency existed between the RFC and the reasoning levels of the occupations identified by the vocational expert, and whether any such error was harmful.
3. Whether the ALJ properly evaluated Copertino's subjective symptoms and adequately explained why his allegations were not entirely consistent with the record.
4. Whether the ALJ's evaluation of the medical-opinion evidence and formulation of the RFC were supported by substantial evidence.

Disposition

affirmed