Summary
The United States District Court for the Western District of North Carolina affirmed the Commissioner of Social Security’s denial of Brittany Byrd Phillips’s application for disability insurance benefits. The court held that the administrative law judge applied the correct legal standards, supported the determination with substantial evidence, adequately evaluated Phillips’s subjective symptoms, and was not required to order a consultative psychological examination.
Holdings
- The ALJ sufficiently explained why Phillips's subjective reports were not fully consistent with the medical evidence and other record evidence, and the ALJ's explanation provided an accurate and logical bridge from the evidence to the conclusion.
- The ALJ was not required to order a psychological consultative examination because the administrative record was sufficient to permit an informed determination of disability.
Questions Presented
- Whether the ALJ adequately explained the finding that Phillips's subjective statements concerning the intensity, persistence, and limiting effects of her symptoms were inconsistent with the record.
- Whether the ALJ was required to order a psychological consultative examination to develop the administrative record.
Disposition
affirmed
Cases Cited (18)
- Drumgold v. Commissioner of Social Security, 144 F.4th 596, 604-05 (4th Cir. 2025)(followed)
- Shinaberry v. Saul, 952 F.3d 113, 120, 123 (4th Cir. 2020)(followed)
- Biestek v. Berryhill, 587 U.S. 97, 98-99, 102-03 (2019)(followed)
- Metcalf v. Schweiker, 795 F.2d 343, 345 (4th Cir. 1986)(followed)
- Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990)(followed)
- Johnson v. Barnhart, 434 F.3d 650, 653 (4th Cir. 2005)(followed)
- Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012)(followed)
- Lester v. Schweiker, 683 F.2d 838, 841 (4th Cir. 1982)(followed)
- Long v. Kijakazi, No. 1:22-CV-00091-KDB, 2022 WL 18026331, at *2-3 (W.D.N.C. Dec. 30, 2022)(followed)
- Boing v. Raleigh & G.R. Co., 87 N.C. 360 (N.C. 1882)(discussed)
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