Tanya A. v. Frank Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the Northern District of Illinois reviewed the Commissioner of Social Security’s denial of Tanya A.’s application for supplemental security income under 42 U.S.C. § 405(g). The court held that the administrative law judge’s step-three Listings analysis and residual functional capacity determination were supported by substantial evidence and free of reversible error. Plaintiff’s motion to reverse was denied, and the Commissioner’s request to affirm was granted.

Holdings

1. The ALJ's Step 3 determination was supported by substantial evidence. Tanya did not establish reversible error in the findings that she failed to satisfy the Paragraph B or Paragraph C criteria of Listings 12.04 and 12.06; the court therefore did not need to resolve whether she satisfied the Paragraph A criteria of Listing 12.06.
2. The ALJ's RFC assessment was supported by substantial evidence and did not contain reversible error.
3. The ALJ adequately considered Tanya's pain complaints and reasonably found that her statements concerning the intensity, persistence, and limiting effects of her symptoms were not entirely consistent with the medical and other evidence.
4. The ALJ did not err by omitting the five-pound restriction because hypotheticals to the vocational expert need include only limitations that the ALJ accepts as credible and supported by the medical record.

Questions Presented

1. Whether the ALJ properly determined that Tanya's impairments did not meet or medically equal Listings 12.04 and 12.06.
2. Whether the ALJ's residual functional capacity assessment was supported by substantial evidence, including the treatment of Dr. Lopez's five-pound lifting restriction, Tanya's pain complaints, and her discontinuation of Depakote.
3. Whether the ALJ improperly failed to include Dr. Lopez's five-pound lifting restriction in the hypothetical questions posed to the vocational expert.
4. Whether the ALJ's Step 5 finding that Tanya could perform other work in the national economy was supported by substantial evidence.

Disposition

affirmed