Sandi Denise White v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania reviewed the Commissioner of Social Security’s denial of Sandi Denise White’s claim for disability insurance benefits. The court held that the ALJ’s residual functional capacity assessment limiting White to light work was supported by substantial evidence, including the medical opinions adopted by the ALJ, and affirmed the Commissioner’s decision.

Holdings

1. An ALJ's failure to perform a function-by-function analysis, standing alone, does not require remand when the RFC determination is otherwise supported by substantial evidence.
2. An RFC limiting a claimant to light work as defined in 20 C.F.R. § 404.1567(b) implicitly addresses the claimant's sitting, standing, and walking abilities, including approximately six hours of standing or walking in an eight-hour workday.
3. The ALJ's determination that White could perform light work with additional restrictions was supported by substantial evidence, and the lack of an express separate standing or walking limitation did not require remand.

Questions Presented

1. Whether the ALJ's residual-functional-capacity determination lacked substantial-evidence support because it did not expressly state standing and walking limitations.
2. Whether the ALJ was required to conduct a separate function-by-function assessment of White's standing and walking abilities.
3. Whether the ALJ improperly omitted standing and walking limitations contained in medical opinions the ALJ found persuasive.

Disposition

affirmed