Summary
This opinion reviews the Social Security Administration’s denial of Denna C.’s applications for disability benefits and supplemental security income. The plaintiff challenges the ALJ’s evaluation of mental limitations, lumbar flexion and stooping, MRI evidence, vocational-expert testimony, and symptom assessment. In the provided text, the court discusses and rejects challenges concerning concentration, persistence, or pace; the lumbar flexion finding and stooping restriction; and the November 2022 lumbar MRI, but the document text ends before the full disposition is shown.
Topics
Practice areas
Questions Presented
- Whether the ALJ adequately accounted for Denna's moderate limitations in concentration, persistence, or pace.
- Whether the ALJ built a logical bridge between reduced lumbar flexion findings and the RFC allowance for occasional stooping.
- Whether the ALJ properly evaluated the November 2022 lumbar MRI without obtaining updated medical-expert review.
- Whether the ALJ properly relied on vocational-expert testimony concerning the existence of jobs in the national economy at Step Five.
- Whether the ALJ properly evaluated Denna's subjective symptoms.
Holdings
- An ALJ need not incorporate every moderate limitation from the worksheet portion of a state-agency psychological opinion verbatim into the RFC when medical consultants have translated those limitations into narrative functional restrictions and the ALJ reasonably adopts those restrictions. The ALJ adequately accounted for Denna's supported mental limitations.
- The ALJ did not commit reversible error by permitting occasional stooping despite a consultative examination showing reduced lumbar flexion.
- The ALJ was not required to obtain additional medical-expert review of the November 2022 MRI, and the MRI did not require remand.
- The Commissioner met the Step Five burden through unchallenged vocational-expert testimony identifying approximately 231,000 jobs nationally, and Denna forfeited her challenge to the reliability or continued existence of the identified occupations by failing to raise it during the administrative proceedings.
- The ALJ's evaluation of Denna's subjective symptoms was not patently wrong and was supported by substantial evidence.
Key quotations
“An ALJ is not required to incorporate every moderate limitation appearing in the worksheet portions of state-agency psychological opinions verbatim into the RFC.” (at 9)
“But that principle applies only where the new evidence is both significant and likely to alter the reviewing physicians’ conclusions.” (at 16)
“The ALJ was not required to sua sponte investigate the continued viability of each occupation where the VE provided uncontradicted testimony that approximately 231,000 jobs existed nationally that Denna could perform under the ALJ's ultimate RFC determination.” (at 19)
Factual background
Denna C. alleged disability based on physical and mental impairments including degenerative disc disease, diabetic neuropathy, obesity, anxiety, depression, and substance-use disorders. The ALJ found that she had not engaged in substantial gainful activity, had severe impairments, and could not perform her past relevant work, but retained a residual functional capacity for restricted light work with simple, repetitive tasks and postural, environmental, and social limitations. Relying on vocational-expert testimony, the ALJ found that approximately 231,000 jobs existed nationally that she could perform.
Procedural history
Denna C. applied for disability benefits and supplemental security income on March 31, 2021, alleging disability beginning November 4, 2020. The SSA denied the claims initially and on reconsideration. An ALJ found her not disabled on February 21, 2024, and the Appeals Council denied review on September 20, 2024. Denna timely sought judicial review, and the district court affirmed the ALJ's decision.