BERSON v. O'MALLEY
2:24-cv-05210
| E.D. Pa. | Jun 30, 2025Background
- Plaintiff, Christine F. B., filed for Disability Insurance Benefits and Supplemental Security Income, alleging disability due to PTSD, substance use disorder, vision impairments, depression, and related conditions starting August 1, 2020.
- Her claims were denied initially and on reconsideration by the Social Security Administration, followed by an unfavorable decision from the Administrative Law Judge (ALJ) after a telephonic hearing.
- The ALJ found Plaintiff had severe impairments but determined that she retained the residual functional capacity (RFC) to perform certain light, unskilled work available in the national economy (e.g., sorter, order caller, photocopy operator).
- Plaintiff filed for judicial review arguing errors in the ALJ’s weighing of certain medical opinions and deficiencies in how Plaintiff’s limitations were reflected in the decision.
- The District Court reviewed the case under the substantial evidence standard and ultimately upheld the ALJ’s denial of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Evaluation of Dr. Lyons’ opinion | ALJ failed to analyze supportability and consistency properly | ALJ addressed both factors sufficiently | ALJ considered both; no error |
| Evaluation of Dr. Gibbings’ opinion | ALJ’s supportability/consistency analysis flawed | ALJ properly evaluated opinion under regulations | ALJ followed standards; no error |
| RFC/hypothetical to VE | ALJ failed to include all relevant visual/mental limitations | Limitations were sufficient and based on evidence | ALJ accounted for limitations; no error |
| Non-disability finding | Decision unsupported by substantial evidence | Decision is supported by evidence | Substantial evidence supports outcome |
Key Cases Cited
- Poulos v. Comm’r of Soc. Sec., 474 F.3d 88 (3d Cir. 2007) (sets deferential standard of substantial evidence for Social Security judicial review)
- Schaudeck v. Comm’r of Soc. Sec. Admin., 181 F.3d 429 (3d Cir. 1999) (reiterates substantial evidence standard and limits court’s review to ALJ’s findings)
- Brown v. Bowen, 845 F.2d 1211 (3d Cir. 1988) (describes the burden-shifting framework for disability claims)
- Heckler v. Campbell, 461 U.S. 458 (1983) (describes method for showing disability and the use of vocational guidelines)
- Pierce v. Underwood, 487 U.S. 552 (1988) (defines "substantial evidence" for judicial review)