Richard N. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois reviewed an Administrative Law Judge’s denial of disability benefits for the period from March 5, 2013, through August 11, 2015. The court held that substantial evidence supported the residual functional capacity determination, including the omission of additional bathroom-break limitations related to the plaintiff’s inflammatory bowel disease, and that the ALJ’s subjective-symptom analysis was not patently wrong. The court granted the Commissioner’s motion for summary judgment and denied the plaintiff’s request for remand.

Holdings

1. An ALJ is not required to include a particular RFC limitation merely because an impairment is classified as severe; the RFC must instead be supported by substantial evidence. The ALJ's omission of additional bathroom-break limitations for Plaintiff's inflammatory bowel disease was supported by substantial evidence.
2. The ALJ's evaluation of Plaintiff's subjective symptoms was not patently wrong and was supported by specific reasons grounded in the record.
3. The second ALJ was not required to adopt the prior ALJ's finding of one extra unscheduled break so long as the new decision was supported by substantial evidence.

Questions Presented

1. Whether the ALJ's residual functional capacity determination was supported by substantial evidence despite omitting limitations for additional or unscheduled bathroom breaks related to Plaintiff's inflammatory bowel disease.
2. Whether the ALJ properly evaluated Plaintiff's subjective symptoms under SSR 16-3p.
3. Whether the ALJ was required to adopt a limitation included in a prior ALJ's decision.

Disposition

affirmed