Michelle M. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York reviews the denial of Michelle M. Mocniak’s application for Social Security disability insurance benefits. The court addresses challenges concerning migraine headaches, subjective symptom evaluation, mental-health limitations in the residual functional capacity assessment, and the step-five vocational determination. The excerpt concludes that the administrative law judge adequately considered the claimant’s limitations, but it ends before the court’s complete discussion of the step-five issue and disposition.

Holdings

1. The ALJ reasonably evaluated plaintiff's migraine headaches and subjective complaints, and substantial evidence supported the finding that the alleged intensity, persistence, and limiting effects of her symptoms were not fully consistent with the medical and other evidence.
2. The ALJ adequately accounted for plaintiff's moderate limitation in adapting or managing herself by limiting her to simple, unskilled work, simple workplace instructions and decisions, tasks of up to four steps, and no production-pace work.
3. Substantial evidence supported the ALJ's step-five determination because the vocational evidence identified approximately 35,000 sorter jobs nationally, and one job existing in the national economy is sufficient to support a finding that the claimant can perform other work.

Questions Presented

1. Whether the ALJ properly evaluated the limiting effects of plaintiff's migraine headaches and subjective complaints.
2. Whether the residual functional capacity adequately accounted for plaintiff's moderate limitation in adapting or managing herself.
3. Whether substantial evidence supported the step-five finding that plaintiff could perform jobs existing in significant numbers in the national economy.

Disposition

other