Andres Sanchez v. Commissioner Social Security
705 F. App'x 95
| 3rd Cir. | 2017Background
- Sanchez applied for Social Security disability and SSI in September 2011, claiming disability from a 2006 workplace back injury; initial denials and reconsideration denials followed and he requested a hearing.
- An ALJ held a hearing in June 2013 (claimant and vocational expert testified; medical records in the record).
- ALJ found severe impairments of spine, neck, and right knee, but no nerve root or spinal cord compromise; right-eye reduced vision was not a loss of central acuity but warranted limiting work at heights/with machinery.
- ALJ assessed an RFC for sedentary, unskilled work with a sit/stand option, no lifting over five pounds, and no work at heights or with machinery.
- Vocational expert testified that about 37,000 national jobs (small products assembly, small hand packaging, patcher) fit the RFC; ALJ denied benefits and Appeals Council denied review.
- District Court affirmed the ALJ; Sanchez appealed to the Third Circuit, which affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ's RFC finding was supported by substantial evidence | ALJ failed to account for visual impairment, overstated ability to sit and ambulate, disregarded pain testimony, and inadequately explained findings | ALJ considered visual limits (excluded heights/machinery), noted cane use but indoor ambulation without cane, credited medical evidence and permissibly discounted some pain testimony | RFC supported by substantial evidence; ALJ adequately considered vision, ambulation, and pain and explained decision |
| Whether substantial number of jobs existed in national economy | VE’s jobs were inconsistent with RFC because small products assembly needs near acuity and packaging/patching may require >5 lb lifting | ALJ relied on VE testimony that jobs permit sit/stand and that claimant had sufficient acuity (better-eye 20/70); even excluding packaging/patching, assembly jobs alone are sufficient | Substantial evidence supports existence of significant jobs (VE testimony adequate; small products assembly plausible given claimant's vision) |
| Whether district court inadequately addressed Sanchez’s opposition to ALJ | District court failed to fully address claimant’s specific objections | Standard of review is same as appellate review; court considered errors and substantial-evidence record | Third Circuit found no reversible error and declined separate review of this contention as unnecessary after affirming ALJ |
Key Cases Cited
- Brown v. Astrue, 649 F.3d 193 (3d Cir. 2011) (scope of appellate review limited to substantial evidence)
- Burnett v. Comm’r of Soc. Sec., 220 F.3d 112 (3d Cir. 2000) (ALJ decision must be supported by substantial evidence and follow required analysis)
- Zirnsak v. Colvin, 777 F.3d 607 (3d Cir. 2014) (definition of substantial evidence standard)
- Rutherford v. Barnhart, 399 F.3d 546 (3d Cir. 2005) (ALJ must pose hypotheticals that accurately portray claimant’s impairments to vocational expert)
- Johnson v. Chater, 108 F.3d 178 (8th Cir. 1997) (10,000 jobs can be "significant" in national economy)