Michael R. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York affirmed the Commissioner of Social Security’s denial of Michael R.’s application for Supplemental Security Income benefits. The court rejected challenges concerning the absence of a sit-stand option in the residual functional capacity assessment and the ALJ’s evaluation of medical opinions. Plaintiff’s motion for judgment on the pleadings was denied, the Commissioner’s motion was granted, and the case was closed.

Holdings

1. The ALJ's decision not to include a sit-stand option in the RFC was supported by substantial evidence because the consultative examiner did not opine that plaintiff required such an option, and courts routinely find that mild to moderate limitations in prolonged sitting or standing are consistent with light work.
2. The ALJ did not improperly substitute lay judgment for medical opinions; he properly considered and weighed all medical opinions, explained the weight afforded, and reasonably incorporated greater restrictions than those suggested by two of the three medical sources.

Questions Presented

1. Whether the ALJ's RFC was supported by substantial evidence where it did not include a sit-stand option.
2. Whether the ALJ improperly substituted his own lay judgment for medical opinions in formulating the RFC.

Disposition

affirmed