Rocco L. Rogers v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of Ohio reviews a Social Security disability benefits denial under 42 U.S.C. § 405(g). The court overrules the plaintiff’s objections, adopts the magistrate judge’s Report and Recommendation, and holds that the Administrative Law Judge’s residual functional capacity assessment was supported by substantial evidence and applied proper legal standards. The court therefore affirms the Commissioner’s decision denying benefits.

Holdings

1. A finding that an impairment is severe at step two does not automatically require a corresponding limitation in the residual functional capacity assessment; the impairment must be shown to affect the claimant's ability to work.
2. The ALJ's RFC determination and denial of benefits were supported by substantial evidence and were made under proper legal standards.
3. The magistrate judge did not improperly create a post hoc rationale because the Report and Recommendation traced reasoning articulated in the ALJ's decision and record.

Questions Presented

1. Whether the ALJ's finding that Plaintiff had a severe pelvic-floor impairment required the residual functional capacity determination to include corresponding physical work limitations.
2. Whether the magistrate judge improperly supplied a post hoc rationale for the ALJ's decision.
3. Whether substantial evidence and proper legal standards supported the Commissioner's denial of disability benefits.

Disposition

affirmed