Joseph M. R. v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of New York reviewed objections to a magistrate judge's Report-Recommendation in a Social Security Disability Insurance case. The court found no clear error, adopted the Report-Recommendation, denied the plaintiff's motion for judgment on the pleadings, granted the Commissioner's motion, affirmed the decision, and directed entry of judgment for the defendant.

Holdings

1. Because plaintiff's objections merely repeated arguments made before the magistrate judge, the district court reviewed the challenged portions for clear error rather than de novo.
2. The ALJ's evaluation of plaintiff's subjective complaints was supported by substantial evidence and was entitled to substantial deference.
3. The ALJ appropriately evaluated the conflicting medical opinion evidence, and the determination that plaintiff could perform less than the full range of light work was supported by substantial evidence.
4. The ALJ satisfied the obligation to investigate and resolve the apparent conflict between the vocational expert's testimony concerning overhead reaching and the Dictionary of Occupational Titles.

Questions Presented

1. Whether the magistrate judge's Report-Recommendation contained clear error in concluding that substantial evidence supported the ALJ's evaluation of plaintiff's subjective complaints.
2. Whether the ALJ adequately evaluated the medical opinion evidence and whether the residual functional capacity determination was supported by substantial evidence.
3. Whether the ALJ adequately investigated and resolved an apparent conflict between the vocational expert's testimony regarding occasional overhead reaching and the Dictionary of Occupational Titles.
4. Whether the vocational expert's identification of approximately 9,000 racker jobs, together with the other identified occupations, supported the step-five determination.

Disposition

affirmed