William Day v. Social Security Administration, Commissioner

Summary

The United States District Court for the Northern District of Alabama reviews William Day’s appeal from the Commissioner of the Social Security Administration’s denial of disability insurance benefits. Applying the substantial-evidence and proper-legal-standards review under 42 U.S.C. § 405(g), the court affirms the Commissioner’s decision and finds that the administrative law judge’s residual functional capacity determination was supported by substantial evidence.

Holdings

1. The ALJ applied the proper multi-part pain standard by finding an underlying medically determinable impairment that could reasonably be expected to produce the alleged symptoms and then evaluating the intensity, persistence, and limiting effects of those symptoms against the medical and other evidence.
2. Substantial evidence supported the ALJ's finding that Day could perform light work with limitations requiring no kneeling, crawling, or ladder, rope, or scaffold climbing; only occasional balancing, crouching, ramp or stair climbing, and stooping; four total hours of standing or walking in an eight-hour day; and no work at unprotected heights or around unguarded moving machinery.
3. The ALJ adequately articulated explicit and adequate reasons for partially discounting Day's subjective testimony, and those reasons were supported by substantial evidence.

Questions Presented

1. Whether the ALJ applied the correct legal standards in evaluating Day's subjective testimony concerning pain and other symptoms.
2. Whether substantial evidence supported the ALJ's residual functional capacity determination limiting Day to a restricted range of light work.
3. Whether the ALJ adequately articulated explicit and adequate reasons for partially discounting Day's subjective testimony.

Disposition

affirmed