Jennifer G. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Western District of Kentucky reviews the Commissioner of Social Security’s denial of Jennifer G.’s applications for disability insurance benefits and supplemental security income. The claimant challenges the Administrative Law Judge’s evaluation of a consultative examiner’s opinion, the residual functional capacity assessment, and the vocational expert’s job-number testimony based on SkillTRAN. The opinion discusses the substantial-evidence standard, medical-opinion evaluation requirements, RFC formulation, and SSR 24-3p’s treatment of vocational evidence.

Holdings

1. The ALJ adequately evaluated Dr. Endo's opinion by addressing its supportability and consistency and reasonably found it unpersuasive.
2. The ALJ's RFC assessment, including the decision not to impose additional reaching, handling, or fingering restrictions, was supported by substantial evidence.
3. The ALJ was not required to independently verify each job number supplied by the vocational expert or investigate an alleged discrepancy with SkillTRAN data that the claimant did not raise after the hearing.
4. Any error in failing to independently verify the vocational expert's job numbers would be harmless because the routing-clerk occupation alone involved approximately 122,000 national jobs, and the claimant did not challenge that occupation.

Questions Presented

1. Whether the ALJ adequately evaluated the persuasiveness of Dr. Endo's medical opinion under the supportability and consistency requirements of 20 C.F.R. § 404.1520c.
2. Whether the ALJ's residual functional capacity assessment was supported by substantial evidence and improperly omitted additional reaching, handling, and fingering limitations.
3. Whether the ALJ was required to independently verify the vocational expert's estimated job numbers or investigate an alleged discrepancy between the vocational expert's testimony and SkillTRAN data.
4. Whether any error concerning the vocational evidence was harmless because the identified routing-clerk occupation alone existed in significant numbers in the national economy.

Disposition

affirmed