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

Summary

The United States District Court for the Western District of Kentucky reviewed the Commissioner's denial of Kimberly R.'s application for disability insurance benefits under 42 U.S.C. § 405(g). The court held that the administrative law judge adequately evaluated the persuasiveness and consistency of a consultative psychologist's opinion under 20 C.F.R. § 404.1520c. The court affirmed the Commissioner's final decision.

Holdings

1. The ALJ complied with 20 C.F.R. § 404.1520c because she compared Dr. Whitten's opinion with medical and nonmedical evidence, explained the lack of support for the marked workplace-stress limitation, and provided an accurate and logical bridge from the evidence to her conclusions.
2. The ALJ properly considered that Dr. Whitten evaluated the claimant during a one-time consultative examination because the regulations permit consideration of the medical-source relationship, including the length, frequency, purpose, and extent of examinations.

Questions Presented

1. Whether the ALJ satisfied the articulation requirement of 20 C.F.R. § 404.1520c by adequately explaining the supportability and consistency of Dr. Whitten's medical opinion.
2. Whether the ALJ improperly relied on the claimant's activities of daily living and selected treatment evidence when finding Dr. Whitten's opinion only partially persuasive.

Disposition

affirmed