Jermon R. v. Frank Bisignano, Commissioner of Social Security

Summary

The opinion addresses judicial review of the Social Security Commissioner’s denial of Jermon R.’s application for disability insurance benefits. The court evaluates the administrative law judge’s treatment of a medical statement, the claimant’s subjective symptoms, and the residual functional capacity assessment under the substantial-evidence standard.

Holdings

1. The ALJ adequately evaluated Dr. Price's statement under the medical-opinion regulations by addressing its supportability and consistency, and the ALJ's cursory discussion was supplemented by the ALJ's detailed discussion of the medical evidence elsewhere in the residual-functional-capacity analysis.
2. The ALJ did not commit harmful error in evaluating Claimant's subjective symptoms because the decision considered the relevant evidence and factors, explained why Claimant was partially credited but not found as limited as alleged, and incorporated supported mental limitations into the RFC.

Questions Presented

1. Whether the ALJ adequately evaluated Dr. Tracy Price's 2017 statement under the regulations governing medical opinions, including the supportability and consistency factors.
2. Whether the ALJ materially mischaracterized Claimant's testimony and inadequately evaluated his subjective symptoms and pain under the applicable regulations and SSR 16-3p.

Disposition

affirmed