Patricia Baptie v. Frank Bisignano, Commissioner of Social Security

Summary

The document is a memorandum opinion and order in Patricia Baptie’s action seeking judicial review of the Commissioner of Social Security’s denial of Disability Insurance Benefits. The court considers whether the ALJ properly evaluated medical opinion evidence and formulated Baptie’s residual functional capacity. It concludes that the ALJ applied the proper legal standards and that substantial evidence supports the decision denying benefits.

Holdings

1. The ALJ properly evaluated Dr. Kellis's medical-source statement because the ALJ addressed the required supportability and consistency factors and reasonably found the extreme limitations unpersuasive.
2. The ALJ was not required to separately analyze Dr. Kellis's November 2022 symptom description or his statements that Baptie was a candidate for disability and unable to return to gainful employment.
3. The ALJ did not err by failing to evaluate DPT Andrew Helber's December 2022 therapy-note statements as medical opinions.
4. The ALJ properly relied on the state-agency reviewing opinions because the ALJ considered subsequent evidence and incorporated additional limitations into the residual functional capacity.
5. The Commissioner's final decision denying Baptie's application for Disability Insurance Benefits is supported by substantial evidence and was reached under proper legal standards.

Questions Presented

1. Whether the ALJ reversibly erred by failing to evaluate statements by Dr. Kellis and physical therapist Andrew Helber as medical opinions.
2. Whether the ALJ properly evaluated Dr. Kellis's April 2024 medical-source statement under the supportability and consistency factors.
3. Whether the ALJ properly relied on state-agency reviewing opinions despite their having been issued before later medical evidence, including the April 2024 EMG and Dr. Kellis's later opinion.
4. Whether substantial evidence supported the ALJ's residual functional capacity determination and finding that Baptie could perform her past relevant work.

Disposition

affirmed