Jordan G. v. Commissioner of Social Security

Summary

Report and Recommendation in a Social Security disability appeal concerning whether the Administrative Law Judge properly evaluated evidence underlying a Veterans Affairs disability determination and whether the administrative record required further development. The court recommends affirming the Commissioner’s decision, finding that the ALJ’s residual functional capacity assessment and non-disability determination were supported by substantial evidence. The recommendation was issued subject to objections under Federal Rule of Civil Procedure 72(b).

Holdings

1. The ALJ did not err in considering the medical evidence underlying the VA's disability determination. Although the VA disability rating itself was not binding or persuasive under the Social Security framework, the ALJ considered the underlying medical evidence, including the evaluation by Dr. Rivero.
2. The ALJ did not err by failing to further develop the record, and an RFC need not correspond precisely to a physician's medical opinion when it is supported by a combination of objective medical and nonmedical evidence.
3. The Commissioner's denial of benefits was supported by substantial evidence and contained no reversible error; affirmance was therefore recommended.

Questions Presented

1. Whether the ALJ properly considered the medical evidence underlying the VA's prior disability determination, including a medical evaluation stating that Plaintiff's headaches caused significant disability.
2. Whether the ALJ erred by failing to fully and fairly develop the administrative record or by formulating the residual functional capacity without a medical opinion corresponding precisely to that RFC.
3. Whether the Commissioner's denial of benefits was supported by substantial evidence and consistent with applicable law.

Disposition

other