Mark J. v. Leland Dudek

Summary

The United States District Court for the Southern District of California reviewed the denial of Plaintiff Mark J.’s applications for disability insurance benefits and supplemental security income. The court held that the ALJ did not reversibly err in treating Plaintiff’s foot issues as non-severe or in declining to evaluate treatment recommendations from the Kafri Heart and Vascular Clinic as medical opinions. The court affirmed the Commissioner’s final decision and ordered judgment for Defendant.

Holdings

1. The ALJ did not commit reversible error in treating Plaintiff's foot issues as non-severe or in declining to impose additional walking and standing limitations. The record did not establish significant functional limitations, did not show that Plaintiff's cane was medically required, and the ALJ considered all of Plaintiff's impairments in determining the residual functional capacity.
2. The Kafri Heart and Vascular Clinic records were other medical evidence, not medical opinions, because they did not state what Plaintiff could still do despite his impairments or identify work-related limitations or restrictions. The ALJ therefore was not required to evaluate their persuasiveness under 20 C.F.R. §§ 404.1520c and 416.920c.

Questions Presented

1. Whether the ALJ erroneously found Plaintiff's foot impairments non-severe and failed to include additional walking and standing limitations in the residual functional capacity.
2. Whether treatment notes from sources at the Kafri Heart and Vascular Clinic were medical opinions requiring evaluation for persuasiveness under the applicable Social Security regulations.

Disposition

affirmed