Laura Ouellette 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 Laura Ouellette’s applications for Supplemental Security Income and Disability Insurance Benefits. The court rejects her challenges concerning the residual functional capacity assessment, evaluation of pain under SSR 16-3p, and consideration of a hand impairment, and affirms the Commissioner’s nondisability determination. The court also finds harmless error in the omission of a state-agency limitation concerning wet, slippery, or uneven surfaces.

Holdings

1. The ALJ's determination that Ouellette could perform restricted light work, including the standing and walking requirements relied on by the vocational expert, was supported by substantial evidence.
2. The ALJ properly evaluated Ouellette's pain and subjective symptoms under SSR 16-3p, and substantial evidence supported the resulting limitations.
3. The ALJ did not commit reversible error by failing to include hand-related limitations in the RFC because the record did not establish a medically determinable hand impairment or a severe impairment.

Questions Presented

1. Whether the ALJ's residual functional capacity assessment adequately supported the standing and walking requirements of light work.
2. Whether the ALJ properly evaluated Ouellette's subjective pain symptoms under SSR 16-3p.
3. Whether the ALJ committed reversible error by failing to treat Ouellette's alleged hand impairment as a medically determinable or severe impairment and include related limitations in the RFC.

Disposition

affirmed