Jenna B. v. Commissioner of Social Security

Summary

This Report and Recommendation addresses Jenna B.’s action under 42 U.S.C. § 405(g) seeking review of the Commissioner of Social Security’s denial of Child Disability Insurance Benefits and Supplemental Security Income. The magistrate judge recommends overruling Plaintiff’s statement of errors and affirming the Commissioner’s decision, concluding that the ALJ properly evaluated the medical opinions and that the decision was supported by substantial evidence. The case also concerns compliance with a prior remand order regarding the evaluation of treating-source opinions.

Holdings

1. The ALJ complied with the prior remand order and reasonably found Joyce Parson's opinions unpersuasive because the proposed extreme limitations were inconsistent with medical records, Plaintiff's reported ability to interact with others, and her ability to maintain part-time employment.
2. The ALJ adequately evaluated the supportability of Freimuth's opinion by considering the opinion's internal explanation and Freimuth's notation that Plaintiff's mood symptoms were well managed.
3. The ALJ adequately evaluated the consistency of Freimuth's opinion by comparing it with Plaintiff's subjective reports and other evidence in the record.
4. The Commissioner's decision denying benefits should be affirmed because it was supported by substantial evidence and made pursuant to proper legal standards.

Questions Presented

1. Whether the ALJ properly evaluated the persuasiveness and consistency of Joyce Parson's medical opinions after the prior district-court remand.
2. Whether the ALJ adequately evaluated the supportability and consistency of Emily Freimuth's medical opinion under the applicable Social Security regulations.
3. Whether the Commissioner's denial of benefits was supported by substantial evidence and made pursuant to proper legal standards.

Disposition

other