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

Summary

The United States District Court for the Western District of Kentucky reviewed the Commissioner of Social Security’s denial of the plaintiff’s claim for Disability Insurance Benefits under 42 U.S.C. § 405(g). The court held that the Administrative Law Judge properly evaluated the plaintiff’s physical and mental impairments, residual functional capacity, and ability to perform past relevant work, and that the decision was supported by substantial evidence. The court affirmed the Commissioner’s final decision and dismissed the complaint.

Holdings

1. Any error in failing to classify PTSD or major depressive disorder as severe, or in more specifically addressing the paragraph-B criteria, was harmless because the ALJ found other severe impairments and the court determined that the step-two findings were supported by substantial evidence.
2. The ALJ was not required to incorporate Plaintiff's mild paragraph-B limitations into the RFC because the record did not establish work-related mental limitations beyond those reflected in the ALJ's assessment.
3. The ALJ did not commit reversible error by finding Plaintiff's mild hip arthritis and decreased hip joint space nonsevere or by declining to impose additional hip-related RFC restrictions.
4. The Commissioner's final decision denying Plaintiff's Disability Insurance Benefits was supported by substantial evidence and comported with applicable law.

Questions Presented

1. Whether the ALJ reversibly erred by finding Plaintiff's anxiety, depression, PTSD, and other mental impairments nonsevere at step two and by failing to include additional mental limitations in the RFC.
2. Whether the ALJ reversibly erred by failing to classify Plaintiff's hip impairment as severe and by failing to include additional hip-related limitations in the RFC.
3. Whether the Commissioner's final decision was supported by substantial evidence and made pursuant to proper legal standards.

Disposition

affirmed