Summary
The United States District Court for the Western District of New York reviews the Commissioner's denial of Melvin J.'s application for Social Security disability benefits. The court addresses the ALJ's evaluation of medical opinion evidence and the step-five finding that the claimant could perform other sedentary jobs existing in significant numbers in the national economy.
Court
United States District Court for the Western District of New York
Jurisdiction
United States District Court for the Western District of New York
Decision date
February 11, 2026
Docket number
23-CV-00160-HKS
Disposition
other
Questions Presented
- Whether the ALJ properly evaluated the supportability and consistency of the medical opinion evidence, particularly the opinion of Dr. Robert M. Ungerer.
- Whether the ALJ properly formulated plaintiff's residual functional capacity without relying exclusively on a medical-source opinion.
- Whether the ALJ properly relied on vocational-expert testimony at step five despite a difference between the vocational expert's testimony and the Dictionary of Occupational Titles regarding the sorter position's specific vocational preparation level.
- Whether the vocational evidence established that a significant number of jobs existed in the national economy that plaintiff could perform.
Holdings
- The ALJ adequately addressed the supportability and consistency of Dr. Ungerer's opinion and did not commit reversible error by finding the opinion only somewhat persuasive and rejecting its four-hour-per-day limitation.
- An ALJ is not required to rely exclusively on a medical-source opinion when articulating a claimant's residual functional capacity, and the ALJ did not create a reversible evidentiary gap here.
- The ALJ properly relied on the vocational expert's testimony concerning the sorter position because the apparent conflict with the DOT was identified and the vocational expert provided a reasonable explanation based on professional experience.
- The vocational evidence identifying approximately 46,000 sorter jobs in the national economy established a significant number of jobs, so the court did not need to resolve plaintiff's additional challenge to the other occupations identified.
Court Document
Open PDFLoading document…