Cecil C. v. Bisignano

Summary

This is an order from the United States District Court for the Northern District of California reviewing an Administrative Law Judge’s denial of Social Security disability benefits. The decision addresses the severity of obesity and chronic back pain, evaluation of subjective symptom testimony, medical opinions, and residual functional capacity. The text contains an apparent inconsistency between the disposition in the caption and the disposition stated in the body of the order.

Holdings

1. The ALJ did not err in finding that Plaintiff's obesity was non-severe because Plaintiff identified no evidence showing that obesity caused a functional limitation or restriction.
2. The ALJ did not err in finding Plaintiff's alleged chronic back pain non-severe; alternatively, any error would have been harmless because the ALJ considered the associated limitations at step four.
3. The ALJ properly evaluated Plaintiff's subjective symptom testimony and provided specific, clear, and convincing reasons for finding that the alleged intensity, persistence, and limiting effects of his symptoms were not entirely consistent with the record.
4. The ALJ properly found the opinions of Dr. Dixit and Dr. Kirsch partially persuasive and reasonably incorporated portions of both opinions into the RFC.
5. The ALJ's RFC determination was supported by substantial evidence and was not based solely on the ALJ's own lay opinion.

Questions Presented

1. Whether the ALJ erred in finding Plaintiff's obesity and alleged chronic back pain non-severe at step two.
2. Whether the ALJ properly evaluated Plaintiff's subjective symptom testimony concerning his physical and mental impairments.
3. Whether the ALJ properly evaluated the persuasiveness of the opinions of Dr. Aparna Dixit and Dr. Nicole Kirsch under the revised medical-evidence regulations.
4. Whether the ALJ's residual-functional-capacity determination was supported by substantial evidence and complied with applicable law.

Disposition

other