Carla M. v. Commissioner of Social Security

Summary

The United States District Court for the Southern District of Ohio reviews the denial of Carla M.'s application for Social Security disability insurance benefits. The court considers challenges to the administrative law judge's step-two findings, residual functional capacity assessment, evaluation of medical-source opinions, and vocational-expert testimony. The court overrules the plaintiff's statement of errors and affirms the Commissioner's decision.

Holdings

1. The ALJ did not commit reversible error by classifying some impairments as non-severe because the ALJ identified other severe impairments and continued through the remaining steps of the sequential evaluation.
2. The ALJ adequately considered the effects of Plaintiff's physical and mental impairments, including alleged non-severe impairments, when formulating the residual functional capacity.
3. The ALJ adequately addressed the supportability and consistency of the opinions of Dr. Kurpita, Dr. Viers, and the state-agency reviewers, and substantial evidence supported the resulting persuasiveness findings.
4. Substantial evidence supported the ALJ's finding that Plaintiff retained the capacity to perform medium work with specified mental and social limitations.
5. The ALJ's failure to expressly include the medium-exertional limitation in the hypothetical question was not reversible error because the vocational expert identified jobs at the medium exertional level and the omission did not alter the outcome.

Questions Presented

1. Whether the ALJ erred in evaluating the severity of Plaintiff's impairments at step two of the sequential evaluation.
2. Whether the ALJ considered all severe and non-severe impairments when formulating Plaintiff's residual functional capacity.
3. Whether the ALJ properly evaluated the medical opinions and prior administrative medical findings under 20 C.F.R. § 404.1520c.
4. Whether substantial evidence supported the ALJ's finding that Plaintiff could perform medium work.
5. Whether the hypothetical question posed to the vocational expert required remand because it did not expressly include the medium-exertional limitation.

Disposition

affirmed