Brenda M. v. Commissioner of Social Security

Summary

A Report and Recommendation from the U.S. District Court for the Northern District of Iowa addressing judicial review of the Commissioner of Social Security’s denial of disability insurance benefits. The magistrate judge recommends affirming the administrative decision, concluding that the ALJ properly assessed the claimant’s mental limitations and invasive lobular carcinoma and adequately developed the record.

Holdings

1. The ALJ was not required to include a specific RFC limitation for adapting or managing oneself merely because the ALJ found a moderate limitation in that paragraph B domain. The paragraph B findings serve a different purpose from the mental RFC assessment, and the ALJ's RFC limitations were supported by the record.
2. The ALJ did not err in considering the claimant's October 2023 diagnosis of stage 1A invasive lobular carcinoma or in declining to obtain additional medical-opinion evidence. The record did not establish work-related symptoms lasting at least twelve months through the December 31, 2023 date last insured, and the claimant declined to supplement the record after the hearing.
3. The Commissioner's denial of disability insurance benefits should be affirmed because the ALJ's decision was supported by substantial evidence on the record as a whole.

Questions Presented

1. Whether the ALJ erred by failing to include a specific RFC limitation corresponding to the moderate paragraph B limitation in adapting or managing oneself.
2. Whether the ALJ erred by finding invasive lobular carcinoma non-severe without further developing the record concerning the expected duration and functional effects of the cancer and its treatment.
3. Whether the ALJ's RFC assessment and resulting denial of disability insurance benefits were supported by substantial evidence.

Disposition

affirmed