Summary
The court affirmed the Commissioner of Social Security’s denial of Marcie K.’s application for disability insurance benefits. It held that the ALJ adequately supported the residual functional capacity determination and that challenges concerning the administration or transcription of witness oaths were waived or harmless.
Court
United States District Court for the Northern District of Illinois, Western Division
Jurisdiction
United States District Court for the Northern District of Illinois, Western Division
Decision date
January 14, 2026
Docket number
3:24-cv-50199
Disposition
affirmed
Questions Presented
- Whether the ALJ's residual functional capacity determination was supported by substantial evidence, including whether the ALJ properly evaluated the psychological consultative examiner's report and incorporated Plaintiff's alleged mental limitations.
- Whether the alleged failure to administer or transcribe an oath or affirmation for Plaintiff and the vocational expert required remand.
- Whether any alleged errors in the administrative hearing were prejudicial or harmless.
Holdings
- A report that merely recites a claimant's subjective complaints and does not assess what the claimant can still do despite an impairment is not a medical opinion under 20 C.F.R. § 404.1513(a)(2); the ALJ therefore was not required to evaluate it under the medical-opinion persuasiveness requirements of 20 C.F.R. § 404.1520c.
- The ALJ's RFC determination was supported by substantial evidence, and Plaintiff failed to identify medical evidence compelling greater mental or social limitations.
- The challenge was waived and, alternatively, any assumed failure to administer or transcribe the oaths was harmless because Plaintiff did not show that the outcome would have differed.
Court Document
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