Hollinger v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of Ohio reviews the Commissioner of Social Security’s denial of Dana Elizabeth Hollinger’s application for Supplemental Security Income. The court rejects challenges concerning consideration of migraines, obesity, residual functional capacity, and symptom evaluation under applicable Social Security Rulings. The court affirms the Commissioner’s nondisability determination and dismisses the complaint.

Holdings

1. The ALJ did not err in considering plaintiff's migraines; the ALJ reasonably found migraines were not a severe impairment due to lack of ongoing significant symptoms or limitations, and any error at step two was harmless because the ALJ proceeded through the sequential evaluation considering all impairments.
2. The ALJ did not err in failing to consider whether migraines equaled Listing 11.02B because migraines were not a severe impairment; even if error occurred, it was harmless because claimant failed to show her migraines equaled the listing.
3. The ALJ properly considered claimant's obesity in formulating the RFC and found the combination of impairments did not equal a listing.
4. The ALJ properly considered plaintiff's symptom allegations in accordance with SSR 16-3p; the ALJ's credibility determination was supported by substantial evidence.

Questions Presented

1. Whether the ALJ properly considered all of claimant's impairments, specifically migraine headaches, under SSR 96-8p in forming the residual functional capacity
2. Whether the ALJ erred at step three by failing to find that claimant's obesity equaled a listing under SSR 19-2p
3. Whether the ALJ properly applied SSR 16-3p in evaluating claimant's symptom testimony

Disposition

affirmed