J.S.B. v. Commissioner, Social Security Administration

Summary

The court affirmed the Commissioner of Social Security’s denial of the plaintiff’s application for disability insurance benefits under 42 U.S.C. § 405(g). Although the court concluded that the ALJ improperly relied on lay judgment in assessing the plaintiff’s residual functional capacity without medical opinion evidence, it held that the plaintiff failed to show prejudice from the denial of a consultative examination. The court entered judgment for the Commissioner on January 6, 2026.

Holdings

1. The ALJ committed a Ripley error by relying on her own lay understanding of medical diagnoses and raw medical data to assess Plaintiff's RFC without substantial evidence establishing the effects of Plaintiff's impairments on his ability to work.
2. The RFC error did not require reversal because Plaintiff failed to show prejudice—specifically, what additional evidence would have been produced and how it might have changed the disability determination.
3. The Commissioner's decision denying benefits was affirmed despite the ALJ's nonprejudicial RFC error.

Questions Presented

1. Whether the ALJ improperly assessed Plaintiff's residual functional capacity by relying on lay interpretation of medical diagnoses and raw medical data in the absence of medical-opinion evidence.
2. Whether the ALJ's failure to obtain a consultative examination or otherwise fully develop the record prejudiced Plaintiff and required reversal or remand.
3. Whether the Commissioner's denial of disability insurance benefits was supported by substantial evidence and proper legal standards.

Disposition

affirmed