Hannah L. v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of New York reviewed the Commissioner of Social Security’s denial of Hannah L.’s application for Disability Insurance Benefits and Supplemental Security Income. The court held that the Administrative Law Judge adequately evaluated the supportability and consistency of a consultative psychologist’s opinion under the applicable regulations and that substantial evidence supported the decision. Plaintiff’s motion for judgment on the pleadings was denied, the Commissioner’s motion was granted, and the decision was affirmed.

Holdings

1. The ALJ adequately explained consideration of the supportability factor by identifying the discrepancies between Dr. Shapiro's marked and extreme limitations and Dr. Shapiro's own examination findings.
2. The ALJ adequately explained the consistency factor by finding that Dr. Shapiro's marked and extreme limitations were inconsistent with the record as a whole, including treatment records documenting improved symptoms and functioning with treatment.
3. The Commissioner's determination that Plaintiff was not disabled is supported by substantial evidence and must be affirmed.

Questions Presented

1. Whether the ALJ adequately explained consideration of the regulatory supportability and consistency factors in evaluating consultative examiner Jeanne Shapiro's medical opinion.
2. Whether substantial evidence supported the Commissioner's determination that Plaintiff was not disabled under the Social Security Act.

Disposition

affirmed