Cortina C. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York reviewed the Commissioner of Social Security’s denial of Plaintiff Cortina C.’s application for Supplemental Security Income. The Court held that the Administrative Law Judge’s residual functional capacity determination and evaluation of the medical opinions were supported by substantial evidence and complied with applicable legal standards. The Commissioner’s motion for judgment on the pleadings was granted, Plaintiff’s motion was denied, and the complaint was dismissed with prejudice.

Holdings

1. The ALJ's determination that Plaintiff could perform a reduced range of light work with specified limitations was supported by substantial evidence.
2. The ALJ properly considered Plaintiff's ability to care for her children, together with medical and treatment evidence, in evaluating the residual functional capacity.
3. The ALJ reasonably limited Plaintiff to occasional interaction with the general public, coworkers, and supervisors.
4. The ALJ adequately addressed, or the record otherwise permitted the court to glean, the supportability and consistency analyses for Brown-Young's and Quinn's opinions; any procedural error was harmless.

Questions Presented

1. Whether the ALJ's residual functional capacity determination was supported by substantial evidence.
2. Whether the ALJ improperly relied on Plaintiff's ability to care for her children.
3. Whether the ALJ adequately evaluated the supportability and consistency of the medical opinions of nurse practitioner Brown-Young and therapist Quinn.
4. Whether the ALJ's limitation to occasional interaction with the public, coworkers, and supervisors was supported by substantial evidence.

Disposition

dismissed