Joshua Spradlin v. Frank Bisignano, Commissioner of Social Security

Summary

This Report and Recommendation addresses Joshua Spradlin’s judicial challenge to the Commissioner of Social Security’s denial of Disability Insurance Benefits under Title II of the Social Security Act. The magistrate judge concludes that the Administrative Law Judge applied proper legal standards and recommends affirming the Commissioner’s decision. The record discusses Spradlin’s physical and psychological impairments, residual functional capacity, medical opinions, and vocational evidence.

Holdings

1. The ALJ properly treated those statements as conclusions on issues reserved to the Commissioner and therefore as inherently neither valuable nor persuasive, without undertaking the ordinary persuasiveness analysis.
2. The ALJ was not required to separately evaluate Bonsky's narrative statements because they primarily recited Spradlin's self-reported symptoms and limitations and did not constitute a medical opinion.
3. The magistrate judge recommended affirming the Commissioner's final decision denying Spradlin's application for Disability Insurance Benefits.

Questions Presented

1. Whether the ALJ properly evaluated PA-C Andrew Bonsky's response to a request for medical information under 20 C.F.R. § 404.1520c.
2. Whether the ALJ's residual functional capacity finding was supported by substantial evidence and proper legal standards.

Disposition

approved