Samuel S. 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 Samuel S.’s application for Disability Insurance Benefits. The court held that the administrative law judge properly found the plaintiff’s mental impairments non-severe at step two, adequately evaluated the medical opinions, and did not fail to develop the record. The court denied the plaintiff’s motion for judgment on the pleadings and granted the Commissioner’s cross-motion.

Holdings

1. The ALJ's finding that Plaintiff's major depressive disorder and generalized anxiety disorder were non-severe was supported by substantial evidence.
2. The ALJ complied with 20 C.F.R. § 404.1520c when evaluating the opinions of Dr. Maria Cartagena and LCSW Brian Rainforth.
3. The ALJ did not have an affirmative obligation to obtain additional treatment records from LCSW Rainforth.

Questions Presented

1. Whether the ALJ erred at step two by finding Plaintiff's major depressive disorder and generalized anxiety disorder non-severe.
2. Whether the ALJ improperly evaluated the opinions of Plaintiff's treating physician and licensed clinical social worker under the medical-opinion regulations.
3. Whether the ALJ failed to develop the administrative record by not obtaining additional treatment records from the licensed clinical social worker.

Disposition

other