Robert C. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Western District of Kentucky reviewed Robert C.’s challenge under 42 U.S.C. § 405(g) to the Commissioner of Social Security’s denial of disability benefits. The court held that the Administrative Law Judge’s residual functional capacity determination was supported by substantial evidence and applied the correct legal standards. The court affirmed the Commissioner’s final decision.

Holdings

1. An ALJ is not required to base the residual functional capacity determination on a medical opinion; the ALJ is responsible for determining RFC from the medical and nonmedical evidence in the record.
2. The ALJ did not impermissibly interpret raw medical data in formulating Plaintiff's RFC because the CT imaging relied upon had been interpreted by a physician, the emergency-room records were reports from medical professionals, and an ALJ may evaluate clinical evidence relating to physical impairments.
3. The RFC was supported by substantial evidence even though the ALJ did not identify a separate affirmative piece of evidence establishing every function not precluded by the RFC.

Questions Presented

1. Whether the ALJ's residual functional capacity determination was supported by substantial evidence even though the ALJ found the only medical opinion in the record unpersuasive.
2. Whether the ALJ improperly interpreted raw medical data or substituted lay judgment for medical opinion in formulating the residual functional capacity.
3. Whether the ALJ was required to identify affirmative evidence separately establishing each functional capacity or explain why Plaintiff could perform functions not precluded by the RFC.

Disposition

affirmed