Shana H. v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of New York reviewed the Commissioner's denial of Shana H.'s application for Social Security disability insurance benefits. The court held that the administrative law judge's findings, including the residual functional capacity assessment, evaluation of medical opinions, and step-five vocational determination, were supported by substantial evidence. Plaintiff's motion for judgment on the pleadings was denied, Defendant's motion was granted, and the Commissioner's decision was affirmed.

Holdings

1. The ALJ did not err by declining to apply the special technique for mental impairments because Plaintiff did not establish a medically determinable impairment causing the reported memory issues.
2. The ALJ's failure to include specific manipulative limitations did not warrant remand because Plaintiff did not identify medical evidence or a proposed functional limitation establishing that more restrictive limitations were required.
3. The ALJ adequately evaluated the consistency of Dr. Comley's opinion with the other evidence and sufficiently explained why the opinion was not persuasive.
4. The ALJ's step-five determination was supported by substantial evidence because the vocational expert testified that a person with Plaintiff's RFC could perform cashier work, and more than 465,000 such positions existed nationally.
5. Any alleged step-four error was harmless because the ALJ's step-five finding was supported by substantial evidence.

Questions Presented

1. Whether the ALJ erred at step two by failing to find Plaintiff's reported memory issues to be a severe impairment or apply the special technique for evaluating mental impairments.
2. Whether the ALJ's residual functional capacity assessment was unsupported because it did not include specific manipulative limitations for diabetic neuropathy and carpal tunnel syndrome.
3. Whether the ALJ improperly evaluated the consistency of treating provider Dr. Shannon Comley's medical opinion.
4. Whether an incomplete or typographical sentence in the ALJ's discussion of the state agency consultants required remand.
5. Whether the ALJ erred at step five by relying on vocational-expert testimony and finding that Plaintiff could perform cashier work existing in significant numbers in the national economy.
6. Whether any alleged step-four error warranted remand despite the supported step-five finding.

Disposition

dismissed