Katherine R. Childress v. Commissioner of Social Security Administration

Summary

The United States District Court for the Northern District of Ohio reviews the Commissioner of Social Security’s denial of Katherine R. Childress’s applications for Supplemental Security Income and Medicare Qualified Government Employee benefits. The court evaluates challenges concerning neuropathy symptoms, anxiety, PTSD, and medical-opinion evidence under 42 U.S.C. § 405(g). The court affirms the Commissioner’s final decision.

Holdings

1. The ALJ did not err in declining to find peripheral neuropathy a severe medically determinable impairment because Childress did not identify objective medical evidence establishing peripheral neuropathy, and the cited EMG showed no electrodiagnostic evidence of peripheral neuropathy.
2. The ALJ's failure to designate anxiety and PTSD as severe impairments was not reversible error because the ALJ found another severe mental impairment and considered Childress's mental symptoms and limitations at subsequent steps of the sequential analysis.
3. The ALJ adequately evaluated the opinions of Dr. Samsa, CNP Raimey, and Dr. Gornik under the current persuasiveness regulations, and substantial evidence supported the findings that the opinions were unpersuasive or only partially persuasive.
4. The ALJ complied with the governing RFC requirements and reasonably determined that Childress could perform restricted light work with four hours of standing or walking, postural and environmental restrictions, and limitations to simple routine work without high production quotas or hourly piece-rate work.

Questions Presented

1. Whether the ALJ erred by failing to designate alleged peripheral neuropathy, anxiety, and PTSD as severe medically determinable impairments at step two.
2. Whether the ALJ properly evaluated the persuasiveness of the medical opinions of Childress's treating providers under 20 C.F.R. § 416.920c.
3. Whether the ALJ's residual functional capacity assessment complied with SSR 96-8p and was supported by substantial evidence.
4. Whether the Commissioner's final decision denying benefits should be affirmed under 42 U.S.C. § 405(g).

Disposition

affirmed