D. A. Shepardson v. Frank J. Bisignano

Summary

The United States District Court for the Northern District of Indiana affirmed the Commissioner of Social Security’s denial of D. A. Shepardson’s applications for disability benefits. The court held that the Administrative Law Judge’s physical and mental residual functional capacity findings and reliance on vocational-expert testimony were supported by substantial evidence, and that Shepardson forfeited a challenge to the vocational expert’s methodology.

Holdings

1. The ALJ's RFC determination was supported by substantial evidence because the ALJ considered the relevant medical and nonmedical evidence, addressed the combined effects of Shepardson's impairments, and incorporated the limitations supported by the record.
2. The ALJ properly discounted Shepardson's alleged greater limitations and found the LCSW's opinions unpersuasive where the allegations and opinions were not supported by objective evidence and were contradicted by the record.
3. Shepardson forfeited the challenge to the vocational expert's methodology because she did not raise it during the administrative proceedings and the issue was not part of the administrative record.
4. The ALJ properly relied on the vocational expert's testimony because the hypothetical questions and RFC incorporated the limitations supported by the record, and Shepardson identified no additional restriction that should have been included.

Questions Presented

1. Whether the ALJ's physical and mental residual-functional-capacity determination was supported by substantial evidence.
2. Whether the ALJ properly evaluated Shepardson's subjective statements and the opinions of a licensed clinical social worker.
3. Whether the ALJ properly relied on vocational-expert testimony at step five.
4. Whether Shepardson preserved a challenge to the vocational expert's methodology and job-number evidence.

Disposition

affirmed