Marianita M. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois reviewed the denial of Marianita M.’s application for disabled widow’s benefits and supplemental security income. The court held that the administrative law judge’s evaluation of her physical and mental impairments, residual functional capacity, and subjective symptom allegations was supported by substantial evidence. Plaintiff’s motion for summary judgment was denied, the Commissioner’s motion was granted, and the denial of benefits was affirmed.

Holdings

1. The ALJ's determination that plaintiff's subjective symptom allegations were not fully credible was not patently erroneous and was supported by substantial evidence.
2. The ALJ's determination that plaintiff could perform simple work despite a moderate limitation in concentration, persistence, or pace was supported by substantial evidence.
3. The ALJ was not required to discuss every piece of evidence or include additional RFC restrictions where the decision demonstrated consideration of the relevant subject matter and plaintiff did not identify evidence requiring greater limitations.

Questions Presented

1. Whether substantial evidence supported the ALJ's determination that plaintiff could perform restricted light work.
2. Whether the ALJ's evaluation of plaintiff's subjective symptom allegations was patently erroneous.
3. Whether the ALJ built a logical bridge from the evidence to the determination that plaintiff could perform simple work despite a moderate limitation in concentration, persistence, or pace.
4. Whether the ALJ adequately considered the combined effects of plaintiff's physical and mental impairments in assessing residual functional capacity.

Disposition

affirmed