Anderson v. Commissioner of the Social Security Administration, 4:23-cv-01131

Plaintiff Jesse Edward Anderson sought judicial review, under 42 U.S.C. § 405(g), after the Social Security Administration (SSA) denied his application for Disability Insurance Benefits (DIB).
Plaintiff initially filed for DIB alleging disability starting May 2013 (later amended to June 2016); his application was denied at all SSA levels, including after a remand from the district court for further proceedings.
After a supplemental ALJ hearing and renewed denial, the case returned to the district court on the plaintiff’s objections to a magistrate judge's new Report and Recommendation (R&R) affirming the denial.
Plaintiff objected, arguing the ALJ improperly discounted his nurse practitioner’s opinions, inadequately considered his physical impairments (especially knee issues), and failed to properly evaluate his subjective complaints.
The district court conducted de novo review of the challenged portions of the magistrate’s R&R and the underlying ALJ decision.
The court ultimately overruled all Plaintiff's objections and affirmed the Commissioner’s denial of benefits.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Weighing NP Stutts’ Opinions	ALJ/Magistrate erred by dismissing nurse practitioner’s opinions without specific citations; evidence supports NP Stutts	ALJ’s finding opinions unpersuasive was supported by the record; Magistrate did not reweigh evidence	Dismissal of NP Stutts’ opinions affirmed; ALJ’s process proper
Physical RFC/Knee Conditions	ALJ failed to properly evaluate severity and limiting effects of Plaintiff’s knee (esp. pre-DLI); evidence shows greater impairment	ALJ properly considered pre- and post-DLI records; evidence supports finding of no severe impairment	ALJ’s physical RFC assessment supported by substantial evidence; affirmed
Evaluation of Subjective Complaints	ALJ did not properly explain rejection of Plaintiff’s subjective symptom complaints, failing to consider true limits of daily activities	ALJ adequately addressed complaints, daily activities, and symptom severity; his findings are supported	ALJ’s evaluation of subjective complaints was legally adequate and supported

Mathews v. Weber, 423 U.S. 261 (1976) (district court must review specific objections to magistrate’s recommendations de novo)
Johnson v. Barnhart, 434 F.3d 650 (4th Cir. 2005) (ALJ findings must be upheld if supported by substantial evidence and correct legal standard)
Craig v. Chater, 76 F.3d 585 (4th Cir. 1996) (standard for evaluating subjective complaints of pain in Social Security cases)
Monroe v. Colvin, 826 F.3d 176 (4th Cir. 2016) (ALJ must provide discussion of what evidence is found credible and why)