R.W. v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of California reviews the Commissioner of Social Security’s denial of R.W.’s applications for disability insurance benefits and supplemental security income. The court rejects R.W.’s arguments that the ALJ failed to develop the record, improperly declined to order a consultative psychological examination, and inadequately evaluated medical opinions. The court denies R.W.’s request for reversal and remand.

Holdings

1. The ALJ did not fail to develop the record because the duty is triggered only by ambiguous evidence or an inadequate record, and the record was adequate to evaluate R.W.'s claims.
2. The ALJ adequately considered both supportability and consistency in evaluating the medical opinions and administrative medical findings.
3. The ALJ properly discounted portions of R.W.'s subjective symptom testimony because she provided clear and convincing reasons supported by substantial evidence.
4. The ALJ was not required to separately enumerate each of the seven strength demands in the written decision, and any omission was harmless.
5. Any error in treating R.W.'s past work as comparable to an automobile-detailer position was harmless because the ALJ alternatively found that other jobs existed in significant numbers that R.W. could perform.

Questions Presented

1. Whether the ALJ failed to discharge the duty to develop the record by not obtaining pre-2014 medical evidence or ordering a consultative psychological examination.
2. Whether the ALJ properly evaluated the supportability and consistency of medical opinions under the revised Social Security regulations.
3. Whether the ALJ adequately evaluated R.W.'s subjective symptom testimony.
4. Whether the ALJ improperly failed to conduct a written function-by-function assessment of all seven strength demands under SSR 96-8p.
5. Whether any error in determining that R.W. could perform his past relevant work required remand despite the ALJ's alternative step-five finding.

Disposition

other