Natalie O. v. Frank Bisignano

Summary

The United States District Court for the Southern District of Indiana reviews the denial of Natalie O.'s applications for Disability Insurance Benefits and Supplemental Security Income. The court rejects her arguments concerning the alleged failure to recognize agoraphobia with panic disorder, the step-three listings analysis, the subjective symptom evaluation, and the residual functional capacity assessment. The court affirms the Commissioner's decision.

Holdings

1. An ALJ's failure to recognize an impairment at step two does not necessarily require remand when the ALJ proceeds through the remaining steps and considers the impairment's limiting effects later in the evaluation.
2. The ALJ's step-three analysis was sufficient because it was more than perfunctory and, when read together with the RFC discussion, adequately explained why the claimant's impairments did not meet or medically equal a listing.
3. The ALJ's subjective-symptom analysis was not patently wrong.
4. The ALJ did not err by omitting a specific public-interaction limitation from the RFC and vocational-expert hypothetical.

Questions Presented

1. Whether the ALJ's failure to expressly identify agoraphobia with panic disorder as a medically determinable impairment at step two required remand.
2. Whether the ALJ adequately evaluated the claimant's mental impairments at step three and properly determined that they did not meet or medically equal a listed impairment.
3. Whether the ALJ's subjective-symptom analysis was patently wrong because it relied on treatment noncompliance without adequately considering reasons for noncompliance, daily activities, or the waxing and waning of chronic conditions.
4. Whether the ALJ's RFC and vocational-expert hypothetical improperly omitted a limitation on interacting with the public.

Disposition

affirmed