Summary
The United States District Court for the Southern District of Indiana overruled Lori Beth J.'s objection to the magistrate judge's report and recommendation in her action seeking review of the Social Security Administration's denial of disability benefits. The court adopted the report and recommendation and affirmed the administrative law judge's decision, concluding that the ALJ properly evaluated the medical opinions, subjective symptom statements, and residual functional capacity under the substantial-evidence standard.
Holdings
- The ALJ's decision to find the opinions of Drs. Huett, Snyder, and Kohn unpersuasive or only partially persuasive was supported by substantial evidence and did not warrant reversal.
- The court declined to review Plaintiff's argument that the ALJ was required to determine whether the medical opinions supported one another because Plaintiff had not presented that argument to the magistrate judge.
- The ALJ properly evaluated Plaintiff's subjective symptom statements, and the credibility determination was not patently wrong.
- The ALJ adequately explained the RFC and supported it with substantial evidence; no additional limitations, including an off-task limitation, were required.
Questions Presented
- Whether the ALJ's evaluation and rejection of portions of the medical opinions of Drs. Huett, Snyder, and Kohn was supported by substantial evidence.
- Whether the ALJ improperly evaluated Plaintiff's subjective symptom statements.
- Whether the ALJ adequately explained the residual functional capacity, including the limitations for concentration, persistence, and pace, full-time work, and an off-task limitation.
- Whether the district court should consider Plaintiff's argument that the ALJ was required to compare the medical opinions with one another when that argument was not presented to the magistrate judge.
Disposition
affirmed
Cases Cited (20)
- Campbell v. Astrue, 627 F.3d 299, 306 (7th Cir. 2010)(followed)
- Biestek v. Berryhill, 587 U.S. 97, 103 (2019)(followed)
- Consol. Edison v. NLRB, 305 U.S. 197, 229 (1938)(followed)
- Roddy v. Astrue, 705 F.3d 631, 636 (7th Cir. 2013)(followed)
- Clifford v. Apfel, 227 F.3d 863, 869, 872 (7th Cir. 2000)(followed)
- Grotts v. Kijakazi, 27 F.4th 1273, 1278 (7th Cir. 2022)(followed)
- Warnell v. O'Malley, 97 F.4th 1050, 1053 (7th Cir. 2024)(followed)
- Stacy S. v. Kijakazi, No. 2:21-cv-395, 2022 WL 2071098, at *3 (S.D. Ind. June 8, 2022)(distinguished)
- Karr v. Saul, 989 F.3d 508, 513 (7th Cir. 2021)(followed)
- Angela J. B. v. Kijakazi, No. 1:21-cv-2801, 2023 WL 2445442, at *4 (S.D. Ind. Mar. 9, 2023)(followed)
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Court Document
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