Lauretta P. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of Washington affirmed the Commissioner of Social Security’s denial of the plaintiff’s application for Disability Insurance Benefits. The court rejected arguments concerning impairment-related work expenses, the Listings and residual functional capacity, newly submitted evidence, and alleged ineffective assistance by prior counsel. The court found no reversible legal error and no basis for remand under sentence six of 42 U.S.C. § 405(g).

Holdings

1. The ALJ did not commit reversible error by failing to discuss impairment-related work expenses because Plaintiff identified no evidence establishing such expenses and, in any event, the omission was harmless after the ALJ proceeded through the remaining steps of the sequential evaluation.
2. The ALJ's findings that Plaintiff did not meet or medically equal a listed impairment and retained the residual functional capacity for a reduced range of light work were supported by substantial evidence.
3. Plaintiff was not entitled to a sentence-six remand because the newly submitted medical evidence was not material to the period adjudicated by the ALJ and did not create a reasonable possibility of a different outcome.
4. Alleged ineffective assistance by counsel representing a claimant in a Social Security proceeding does not itself establish a basis for remand; at minimum, the claimant must show counsel's deficiency caused prejudice or unfairness in the administrative proceeding.

Questions Presented

1. Whether the ALJ's failure to discuss possible impairment-related work expenses required reversal or remand.
2. Whether substantial evidence supported the ALJ's findings that Plaintiff did not meet or medically equal a listed impairment and retained the residual functional capacity for a reduced range of light work.
3. Whether newly submitted medical evidence warranted a sentence-six remand under 42 U.S.C. § 405(g).
4. Whether alleged ineffective assistance by Plaintiff's agency-level counsel warranted remand.

Disposition

affirmed