Summary
The United States District Court for the Western District of New York reviewed the Commissioner of Social Security’s denial of Shannon S.’s application for Disability Insurance Benefits. The court held that the Administrative Law Judge properly evaluated the medical opinion of PA-C Lauren Marino and that the residual functional capacity determination was supported by substantial evidence. The court denied the plaintiff’s motion for judgment on the pleadings, granted the Commissioner’s cross-motion, and dismissed the complaint.
Holdings
- The ALJ adequately addressed the supportability and consistency factors required by 20 C.F.R. § 404.1520c and reasonably found Marino's opinions regarding off-task time and absences unpersuasive.
- The ALJ's RFC determination and finding that Shannon S. was not disabled were supported by substantial evidence and were not the product of legal error.
Questions Presented
- Whether the ALJ adequately evaluated the supportability and consistency of PA-C Lauren Marino's medical opinion under 20 C.F.R. § 404.1520c.
- Whether the ALJ's residual functional capacity determination and finding of no disability were supported by substantial evidence.
Disposition
dismissed
Cases Cited (15)
- Arnone v. Bowen, 882 F.2d 34, 37-38 (2d Cir. 1989)(followed)
- Johnson v. Bowen, 817 F.2d 983, 985-86 (2d Cir. 1987)(followed)
- Moran v. Astrue, 569 F.3d 108, 112 (2d Cir. 2009)(followed)
- Cruz v. Sullivan, 912 F.2d 8, 11 (2d Cir. 1990)(followed)
- Richardson v. Perales, 402 U.S. 389, 401 (1971)(followed)
- Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)(followed)
- Brault v. Social Security Administration, Commissioner, 683 F.3d 443, 448 (2d Cir. 2012)(followed)
- McIntyre v. Colvin, 758 F.3d 146, 149 (2d Cir. 2014)(followed)
- Angela H.-M. v. Commissioner of Social Security, 631 F. Supp. 3d 1, 7 (W.D.N.Y. 2022)(followed)
- Spottswood v. Kijakazi, 2024 WL 89635, at *2 (2d Cir. Jan. 9, 2024)(followed)
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Cited In (0)
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Court Document
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