Latonya J. v. Commissioner of Social Security

Summary

This Report and Recommendation addresses a Social Security appeal challenging the denial of supplemental security income benefits. The magistrate judge recommends affirming the Commissioner’s decision, concluding that the ALJ properly formulated the residual functional capacity and adequately considered the claimant’s impairments, including peripheral neuropathy. The document advises that objections may be filed under Federal Rule of Civil Procedure 72(b).

Holdings

1. The ALJ did not reversibly err by formulating an RFC that used different language from the state-agency psychologists' limitation to brief, infrequent, and superficial contact. The RFC's restrictions to superficial interaction, no public interaction, no tandem work, and no negotiating, instructing, persuading, or directing adequately accommodated the opinions.
2. The ALJ did not commit reversible error in evaluating Plaintiff's alleged right-hand arthritis and peripheral neuropathy. The record did not establish right-hand arthritis as a medically determinable impairment, and the ALJ considered the peripheral neuropathy evidence in assessing the RFC. Any error in classifying peripheral neuropathy as non-severe would be harmless because the ALJ found other severe impairments and proceeded through the sequential analysis while considering the limiting effects of all impairments.

Questions Presented

1. Whether the ALJ's residual functional capacity assessment was inconsistent with the prior administrative medical findings that Plaintiff could handle only brief, infrequent, and superficial contact with supervisors, coworkers, and the public.
2. Whether the ALJ failed to properly evaluate Plaintiff's alleged right-hand arthritis and peripheral neuropathy, including whether the impairments were medically determinable and whether they required additional functional limitations.

Disposition

other