Cathleen M. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York upheld the Commissioner of Social Security’s denial of disability benefits to the plaintiff. The court rejected challenges concerning the plaintiff’s ability to perform past relevant work, consideration of a closed period of disability, and evaluation of her impairments. Plaintiff’s motion for judgment on the pleadings was denied, and the Commissioner’s motion was granted.

Holdings

1. The ALJ properly found that the plaintiff could perform her past relevant work as an accounting clerk as that work is generally performed in the national economy.
2. The plaintiff was not entitled to remand or benefits for a closed period because she did not request such relief during the administrative proceedings, her attorney rejected the proposed closed period when the ALJ raised it, and the evidence did not establish disability through September 22, 2022.
3. The ALJ adequately considered the plaintiff's left-hip symptoms as part of her back-related impairment and did not fail to consider the cumulative impact of the plaintiff's impairments.

Questions Presented

1. Whether substantial evidence supported the ALJ's finding that the plaintiff could perform her past relevant work as an accounting clerk.
2. Whether the ALJ erred by failing to consider or award a closed period of disability from July 23, 2021, through September 22, 2022.
3. Whether the ALJ failed to consider the plaintiff's left-hip impairment and the cumulative effect of her impairments.

Disposition

affirmed