Alesia W. v. Commissioner of the Social Security Administration

Summary

This Report and Recommendations addresses Alesia W.’s challenge to the denial of her applications for Disability Insurance Benefits and Supplemental Security Income. The magistrate judge recommends upholding the Administrative Law Judge’s decision, concluding that the ALJ properly evaluated the medical opinions, Listing 7.18, and the residual functional capacity determination. The document concerns judicial review under the substantial-evidence standard.

Holdings

1. The ALJ did not err in finding Dr. Rowland's opinion persuasive while including a limitation to simple tasks rather than expressly using the phrase clear, simple instructions. The ALJ also was not required to analyze statements that Plaintiff was disabled because the ultimate disability determination is reserved to the Commissioner and the statements did not identify specific functional limitations.
2. The ALJ did not commit reversible error by failing to specifically discuss Listing 7.18 because the record did not raise a substantial question that Plaintiff could satisfy every requirement of that listing, including a marked limitation in activities of daily living, social functioning, or task completion.
3. Substantial evidence supported the ALJ's RFC limiting Plaintiff to sedentary work with specified postural, environmental, driving, and simple-task restrictions.

Questions Presented

1. Whether the ALJ properly evaluated the consultative psychological opinion of Susan Rowland, Ph.D., particularly the distinction between a limitation to simple tasks and a limitation to clear, simple instructions.
2. Whether the ALJ reversibly erred by failing to specifically discuss whether Plaintiff's hemophilia A carrier status and related symptoms met or medically equaled Listing 7.18.
3. Whether substantial evidence supported the ALJ's residual functional capacity determination, including the treatment of Plaintiff's fatigue, anemia, cardiac conditions, menorrhagia, and hysterectomy.
4. Whether the ALJ properly addressed the narrative statements of treating physician Amy L. Dunn, M.D., and social worker Linda Vo.

Disposition

other