Elizabeth D. Costin v. Commissioner of Social Security, sued as Frank Bisignano

Summary

The United States District Court for the Northern District of Indiana reviewed Elizabeth D. Costin’s challenge to the Commissioner of Social Security’s denial of Disability Insurance Benefits. The court held that the administrative law judge properly accounted for Costin’s moderate limitations in concentration, persistence, or pace, adequately explained the residual functional capacity determination, and was not required to order a consultative mental evaluation. The court affirmed the Commissioner’s decision and directed entry of judgment for the Commissioner.

Holdings

1. The ALJ adequately accounted for Costin's moderate limitation in concentration, persistence, or pace by limiting her to carrying out simple instructions and explaining how that restriction addressed her anxiety, abnormal attention and concentration, and potential panic-related stressors.
2. The ALJ built a logical bridge from the evidence to the mental RFC and did not improperly cherry-pick the record, make independent medical findings, or omit necessary social restrictions.
3. The ALJ sufficiently explained the persuasiveness of the two mental medical opinions of record under 20 C.F.R. § 404.1520c.
4. The ALJ was not required to obtain a consultative mental evaluation because the existing record was sufficient to determine Costin's RFC.

Questions Presented

1. Whether the ALJ adequately accounted for Costin's moderate limitation in concentration, persistence, or pace in the RFC.
2. Whether the ALJ built a logical bridge from the evidence to the mental RFC, including by evaluating contrary evidence, adaptation and self-management, and social limitations.
3. Whether the ALJ sufficiently explained the persuasiveness of the mental medical opinions under 20 C.F.R. § 404.1520c.
4. Whether the ALJ was required to obtain a consultative mental evaluation to develop the record.

Disposition

affirmed