BROWN v. COMMISSIONER OF SOCIAL SECURITY, 3:24-cv-00142

Plaintiff, Taniesha Nicole Brown, filed for supplemental security income (SSI) and disability insurance benefits (DIB), alleging disability from April 16, 2020, due to several physical and mental impairments.
The Administrative Law Judge (ALJ) recognized severe impairments (cervical/lumbar degenerative disc disease, obesity, depression, anxiety, hoarding disorder, PTSD) but found Brown could perform a limited range of sedentary work.
The ALJ's decision relied on medical opinion evidence and a functional capacity evaluation (FCE), but did not adopt all limitations stated in the FCE.
A vocational expert (VE) testified that an individual with Brown’s limitations could perform specific sedentary jobs existing in significant numbers in the national economy.
Brown challenged the ALJ’s decision in federal district court, arguing errors in evaluating medical and VE evidence, and in assessing daily activities and pain.
The district court reviewed the record, upheld the ALJ’s determinations, denied Brown's motion for summary judgment, and granted the Commissioner’s cross-motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ALJ’s Use of FCE/VE Testimony	ALJ credited FCE but failed to include all its limitations in RFC and ignored VE’s testimony based on those limits	ALJ was not required to adopt all FCE limitations or credit hypothetical beyond RFC; adopted only those supported by record	ALJ’s evaluation was supported by substantial evidence; no error
Evaluation of Daily Activities and Pain	ALJ erred by overemphasizing minimal daily activities and underestimating pain severity	ALJ properly used full record and minimal activities only as one factor in overall credibility and pain assessment	Substantial evidence supports ALJ’s assessment
Standard for Review/Substantial Evidence	Record supports more restrictive limitations than ALJ found	Standard is whether substantial evidence supports ALJ, not Plaintiff’s position; more restrictive evidence need not control	Court’s role is limited; ALJ’s finding supported by substantial evidence
Extent ALJ must Adopt Persuasive Opinions	ALJ must adopt all persuasive opinions/verbatim FCE findings	ALJs may find an opinion persuasive but need not adopt every limitation; not required to reject omitted findings explicitly	ALJ did not err in adopting only supported limitations

Allen v. Bowen, 881 F.2d 37 (3d Cir. 1989) (Affirms the substantial evidence standard for judicial review of Social Security decisions)
Jesurum v. Sec’y of Health & Human Servs., 48 F.3d 114 (3d Cir. 1995) (Clarifies that substantial evidence means less than a preponderance and may support ALJ’s finding even if evidence also supports claimant)
Richardson v. Perales, 402 U.S. 389 (1971) (Defines substantial evidence and its role in administrative law review)