Barbara Ann Harrington v. Commissioner of Social Security

Summary

This Report and Recommendation addresses Barbara Ann Harrington’s challenge to the Commissioner of Social Security’s denial of Period of Disability and Disability Insurance Benefits. The magistrate judge concluded that the Administrative Law Judge properly evaluated Harrington’s impairments and residual functional capacity, including her mild mental limitations, and recommended affirming the decision and closing the case.

Holdings

1. An ALJ is not required to reanalyze verbatim each of the four broad psychiatric-review-technique areas or automatically translate mild step-two findings into specific RFC restrictions, so long as the ALJ separately provides a detailed and itemized assessment of the claimant's functionality and considers all medically determinable impairments in the RFC analysis.
2. The ALJ's RFC assessment and denial of benefits were supported by substantial evidence and proper legal standards because the ALJ considered the claimant's mental impairments, evaluated the medical opinions and treatment records, and found that she could perform her past relevant work.

Questions Presented

1. Whether the ALJ was required to incorporate specific mental limitations corresponding to mild psychiatric-review-technique findings into the RFC.
2. Whether the ALJ adequately explained the relationship between the step-two psychiatric-review-technique findings and the RFC determination.
3. Whether substantial evidence and proper legal standards supported the ALJ's denial of benefits.

Disposition

other