Dean Vincent D. 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 the plaintiff’s applications for disability insurance and supplemental security income benefits. The court granted the Commissioner’s motion for judgment on the pleadings and denied the plaintiff’s motion, concluding that the ALJ’s residual functional capacity determination was supported by substantial evidence.

Holdings

1. The ALJ did not commit reversible error by declining to include an additional absenteeism limitation for plaintiff's lymphoma infusions because plaintiff identified no evidence establishing the duration of the infusions, that they could not be scheduled around work, or that they would require full-day or unscheduled absences.
2. The ALJ's RFC determination was supported by substantial evidence, and the ALJ was not required to include a sit/stand option.
3. The ALJ adequately explained her consideration of the supportability and consistency factors for the medical opinions.

Questions Presented

1. Whether the ALJ adequately considered the effect of plaintiff's expected lymphoma infusion treatments on potential absenteeism and employability.
2. Whether substantial evidence supported the ALJ's RFC determination without including a sit/stand option.
3. Whether the ALJ adequately explained her consideration of the supportability and consistency of the medical opinions.

Disposition

other