Gwenette Jackson v. Commissioner of Social Security

Summary

This Report and Recommendation addresses Gwenette Jackson’s challenge under 42 U.S.C. § 405(g) to the Commissioner of Social Security’s denial of her applications for Period of Disability and Disability Insurance Benefits. The magistrate judge recommends affirming the Commissioner’s decision, concluding that the administrative law judge properly evaluated the opinion evidence and that the decision was supported by substantial evidence.

Holdings

1. The ALJ properly found Dr. Fernandez's opinion only partially persuasive and adequately explained why the proposed limitation to brief and superficial interactions was not fully supported, while accounting for Jackson's social limitations by restricting her to occasional interaction with coworkers and the public.
2. The ALJ properly found Dr. Hochman's opinion unpersuasive because the proposed lifting, carrying, pushing, pulling, and off-task limitations were overstated or unsupported by the record, while recognizing that some of the opinion's limitations were supported.
3. The Commissioner's final decision denying Jackson's applications was supported by substantial evidence and made under proper legal standards; the magistrate judge therefore recommended affirmance.

Questions Presented

1. Whether the ALJ properly evaluated the persuasiveness of the state-agency psychological opinion concerning Jackson's social-interaction limitations under 20 C.F.R. § 404.1520c.
2. Whether the ALJ properly evaluated the persuasiveness of Dr. Hochman's medical source opinion concerning Jackson's physical limitations and alleged off-task time under 20 C.F.R. § 404.1520c.
3. Whether substantial evidence and proper legal standards supported the ALJ's residual-functional-capacity finding and determination that Jackson was not disabled.

Disposition

affirmed