Jacqueline B. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Southern District of Ohio reviews a challenge to the denial of Disability Insurance Benefits. The Court overrules Plaintiff’s objection to the Magistrate Judge’s Report and Recommendation, concluding that the ALJ properly evaluated the medical opinions and that the decision was supported by substantial evidence. The Court adopts the Report and Recommendation and affirms the Commissioner’s decision.

Holdings

1. The ALJ adequately evaluated the supportability of Dr. Twehues's opinion by explaining that her conclusions regarding distraction, absenteeism, and coping with workplace stress were not sufficiently supported by her own psychological assessment and mental-status examination and were based substantially on Plaintiff's self-reported symptoms and limitations.
2. The magistrate judge did not improperly create a post hoc rationale because the ALJ's decision expressly discussed Dr. Twehues's reliance on Plaintiff's self-reported symptoms and limitations, even though it did not use the phrase 'subjective complaints.'
3. The Commissioner's decision denying Disability Insurance Benefits was supported by substantial evidence.

Questions Presented

1. Whether the ALJ properly evaluated the supportability of consultative psychologist Jessica Twehues's medical opinion under 20 C.F.R. § 404.1520c.
2. Whether the magistrate judge improperly relied on a post hoc rationale in determining that the ALJ permissibly discounted portions of Dr. Twehues's opinion.
3. Whether the Commissioner's denial of Disability Insurance Benefits was supported by substantial evidence.

Disposition

affirmed