Lisa N. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York reviewed a Social Security disability benefits appeal under 42 U.S.C. § 405(g). The court upheld the Commissioner’s denial of benefits, concluding that the ALJ’s residual functional capacity assessment and evaluation of the medical opinions were supported by substantial evidence. Plaintiff’s motion for judgment on the pleadings was denied, and the Commissioner’s motion was granted.

Holdings

1. The ALJ's sedentary residual functional capacity determination, with additional postural and hazard limitations, was supported by substantial evidence, and the record did not require a different result.
2. The ALJ properly evaluated the medical opinions by considering their supportability and consistency and permissibly found the state-agency reviewers' opinions most persuasive and the opinions of Drs. Magurno and Hernandez-Hermann less persuasive.
3. The ALJ did not improperly cherry-pick the evidence.
4. The ALJ's failure to expressly identify every detail of Plaintiff's initial physical-therapy functional testing did not require remand.
5. Remand was not required because the ALJ rejected Dr. Hernandez-Hermann's opinion as a whole as unsupported, which necessarily rejected the proposed hourly position-change limitation, and the record did not support that limitation.

Questions Presented

1. Whether the ALJ's residual functional capacity determination was supported by substantial evidence.
2. Whether the ALJ properly evaluated the persuasiveness of the medical opinions under the applicable regulations, including the supportability and consistency factors.
3. Whether the ALJ improperly relied on non-examining agency medical consultants while disregarding the opinions of the consultative examining physician and treating physician.
4. Whether the ALJ erred by failing to expressly discuss Plaintiff's initial physical-therapy functional testing.
5. Whether remand was required because the ALJ failed to expressly address the treating physician's opinion that Plaintiff needed to change positions every hour.

Disposition

affirmed