M.M. v. Martin O'Malley

Summary

The United States District Court for the Northern District of California reviews a Social Security disability benefits denial. The court holds that the Administrative Law Judge adequately evaluated the claimant’s mental impairments, residual functional capacity, medical opinions, and the administrative record. The court affirms the Commissioner’s decision.

Holdings

1. The ALJ did not err in finding that Plaintiff's mental impairments, considered singly and in combination, did not meet or medically equal Listings 12.02, 12.06, or 12.15. The ALJ reasonably discounted the consultative opinion finding a marked limitation in concentration, persistence, or pace, and any error concerning that single marked limitation would have been harmless because the paragraph B criteria require two marked limitations or one extreme limitation.
2. The ALJ did not err in finding that Plaintiff could perform light work with additional limitations.
3. The ALJ did not violate the duty to develop the record because the evidence was not ambiguous and the record was adequate for evaluation of Plaintiff's claim.

Questions Presented

1. Whether the ALJ properly determined that Plaintiff's mental impairments did not meet or medically equal a listed impairment.
2. Whether substantial evidence supported the ALJ's residual functional capacity determination.
3. Whether the ALJ failed to fully and fairly develop the administrative record.

Disposition

affirmed