Summary
The United States District Court for the Western District of New York reviewed the denial of Robert E.W., Jr.’s application for disability insurance benefits. The court held that the Administrative Law Judge’s residual functional capacity assessment was supported by substantial evidence and that the ALJ did not fail to develop the record concerning an alleged hearing impairment; Plaintiff’s motion was denied and the Commissioner’s motion was granted.
Holdings
- The ALJ's residual functional capacity determination was supported by substantial evidence. The ALJ could formulate specific handling, fingering, and visual-acuity restrictions from the record as a whole, including Plaintiff's testimony, treatment records, and medical opinion evidence, even though no single medical opinion mirrored the precise restrictions.
- The ALJ did not fail to develop the record because the agency made reasonable efforts to obtain relevant records, the record contained evidence addressing Plaintiff's hearing, and Plaintiff did not allege hearing-related functional limitations during the administrative proceedings.
Questions Presented
- Whether the ALJ's highly specific residual functional capacity limitations were supported by substantial evidence and properly tethered to the administrative record.
- Whether the ALJ failed to develop the administrative record concerning Plaintiff's alleged hearing impairment.
Disposition
dismissed
Cases Cited (19)
- Bowen v. City of N.Y., 476 U.S. 467, 470-71(cited)
- Talavera v. Astrue, 697 F.3d 145, 151(cited)
- Rutherford v. Schweiker, 685 F.2d 60, 62(cited)
- Bonet ex rel. T.B. v. Colvin, 523 Fed.Appx. 58, 58-59(cited)
- Brault v. Social Sec. Admin., Comm'r, 683 F.3d 443, 448(cited)
- Tiffany L. v. Comm'r of Soc. Sec., No. 1:20-CV-0677 (WBC), 2021 WL 3145694, at *4(cited)
- Cook v. Comm'r of Soc. Sec., 818 F. App'x 108, 109-10(cited)
- Jennifer O. v. Comm'r of Soc. Sec., No. 1:20-CV-1474 (WBC), 2022 WL 2718510, at *4(cited)
- Rubin v. Martin O'Malley, Comm'r of Soc. Sec., 116 F.4th 145, 155(cited)
- Emmett K. v. Comm'r of Soc. Sec., No. 23-CV-6036-FPG, 2024 WL 445504, at *2(cited)
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Court Document
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