Samuel L. Kawecki v. Commissioner of Social Security

Summary

This Report and Recommendation addresses Samuel L. Kawecki’s challenge to the Commissioner of Social Security’s denial of Disability Insurance Benefits and Supplemental Security Income. The magistrate judge concludes that the ALJ’s failure to expressly address the supportability of state-agency medical and psychological opinions was harmless because the RFC adopted the consultants’ limitations and imposed additional restrictions. The recommendation is that the district court affirm the Commissioner’s final decision.

Holdings

1. The ALJ failed to address the supportability factor adequately, but the error was harmless because the RFC adopted the restrictions identified by the state-agency medical consultants and imposed additional manipulative limitations.
2. Any inadequacy in the ALJ's explanation of the supportability and consistency of the state-agency psychologists' opinions was harmless because the RFC fully encompassed the limitations identified by those psychologists.
3. The ALJ was not required to perform a drug-addiction-and-alcoholism materiality determination under SSR 13-2p because the ALJ found Kawecki not disabled even when considering his substance-use disorder and all other impairments.

Questions Presented

1. Whether the ALJ's failure to expressly address the supportability of the state-agency medical consultants' opinions was harmless when the RFC adopted their restrictions and added further limitations.
2. Whether the ALJ adequately evaluated the state-agency psychologists' opinions and whether any deficiency was harmless because the RFC fully encompassed their stated limitations.
3. Whether the ALJ was required to determine the materiality of Kawecki's substance-use disorder under SSR 13-2p when the ALJ found him not disabled even considering all impairments.

Disposition

other