Todd B. v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois affirmed the Commissioner of Social Security’s denial of Todd B.’s applications for disability insurance benefits. The court rejected challenges concerning the evaluation of subjective symptoms, adjustment disorder, and obesity, concluding that the ALJ’s residual functional capacity finding was supported by substantial evidence and adequately explained.

Holdings

1. The ALJ's evaluation of Plaintiff's subjective symptoms was not patently wrong because the ALJ considered the relevant regulatory factors and adequately explained the decision to find that Plaintiff's symptoms were not as limiting as alleged.
2. The ALJ adequately considered Plaintiff's adjustment disorder and mild limitation in concentration, persistence, or maintaining pace, and substantial evidence did not require additional RFC restrictions.
3. The ALJ adequately considered the effects of Plaintiff's obesity and incorporated obesity-related restrictions into the RFC.
4. The Commissioner's final decision denying benefits was supported by substantial evidence and did not result from legal error.

Questions Presented

1. Whether the ALJ improperly evaluated Plaintiff's subjective symptoms.
2. Whether the ALJ inadequately considered Plaintiff's adjustment disorder and resulting concentration, persistence, or pace limitations in determining the residual functional capacity.
3. Whether the ALJ inadequately considered the effects of Plaintiff's obesity in determining the residual functional capacity.
4. Whether the ALJ's residual functional capacity determination and resulting denial of benefits were supported by substantial evidence.

Disposition

affirmed