Lashonda W. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Indiana reviews the denial of Lashonda W.'s applications for Disability Insurance Benefits and Supplemental Security Income. The court holds that the Administrative Law Judge adequately evaluated the medical evidence, assessed the claimant's residual functional capacity, and addressed the alleged need for a service animal. The court affirms the Commissioner's decision denying benefits.

Holdings

1. The ALJ adequately explained the persuasiveness of the opinions of the medical experts who testified at the hearing by addressing their longitudinal review of the record, supporting rationale, questioning at the hearing, and consistency with the clinical findings and treatment history.
2. The ALJ erred by stating that the consultative examination did not mention reduced range of motion or right-upper-extremity limitations, but the error was harmless because the record permitted the court to predict with great confidence that the ALJ would reach the same result on remand.
3. The RFC and the determination that Plaintiff could perform her past relevant work as a housekeeping cleaner were supported by substantial evidence.
4. The ALJ did not commit reversible error in declining to include a service-animal limitation because Plaintiff did not establish that an animal was medically necessary; any factual error concerning whether the record mentioned an animal was harmless.

Questions Presented

1. Whether the ALJ adequately evaluated the persuasiveness of the medical evidence and opinions under 20 C.F.R. § 404.1520c.
2. Whether the ALJ's RFC assessment failed to include physical limitations identified in a consultative examination.
3. Whether the ALJ's treatment of Plaintiff's alleged need for a service or emotional-support animal required remand.
4. Whether substantial evidence supported the Commissioner's denial of benefits.

Disposition

affirmed