Bruni v. Astrue, 1:09-cv-00743

Bruni sought disability insurance benefits under Title II after applying in April 2007 with alleged onset March 1, 2006; the application was denied in November 2007 and again on reconsideration in February 2008.
A December 9, 2008 hearing before an ALJ (unrepresented by counsel) resulted in an April 29, 2009 decision denying benefits.
The Appeals Council denied Bruni’s request for review on August 14, 2009; Bruni filed suit in October 2009 seeking judicial review, with cross-motions for summary judgment filed in 2010.
Bruni’s medical history includes Crohn’s disease (periods of activity and inactivity), COPD, obesity, depression, sleep disturbances, allergic rhinitis, and chronic back pain; treatment by Drs. Magat, Manalo, Butt, Lifrak, and others is noted.
The ALJ found three severe impairments (Crohn’s disease, COPD, obesity) and several non-severe impairments; Bruni’s Crohn’s disease was described as clinically inactive during the relevant period, supporting an RFC for unskilled light work.
The ALJ concluded Bruni could perform past relevant work or other work in the national economy and was not disabled through April 29, 2009; Bruni challenged the decision, leading to the current judicial review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Duty to develop the record given unrepresented status	Bruni argues ALJ failed to adequately develop the record.	ALJ fulfilled record development, including directing Bruni to obtain records; later records were added.	ALJ satisfied development duties; no remand required.
Severity finding for osteoarthritis, sleep disturbances, depression	ALJ erred in deeming these conditions non-severe.	Evidence supports non-severity; proper application of regulations.	Substantial evidence supports ALJ’s non-severe findings.
Weight given to treating physician’s opinion	ALJ gave insufficient deference to Dr. Magat’s opinions.	Dr. Magat’s opinions were largely unsupported or inconsistent with record; ALJ properly weighed.	ALJ’s treatment of Dr. Magat’s opinions upheld; not reversible.
Weight and consideration of consulting physician Lifrak vs Goldsmith	ALJ should rely on Lifrak’s sedentary limitations.	ALJ weighed Goldsmith’s review more heavily due to record consistency; substantial evidence supports light work RFC.	ALJ’s reliance on Goldsmith over Lifrak sustained.
Crohn’s disease in hypothetical to VE	Hypothetical failed to include Crohn’s-related bathroom needs.	Crohn’s was clinically inactive; not credibly disabling at issue; hypothetical appropriate.	Hypothetical appropriate; VE testimony supports RFC.

Sims v. Apfel, 117 S. Ct. 441 (U.S. 1995) (ALJ's duty to develop record; evaluation of unrepresented claimants)
Hummel v. Heckler, 736 F.2d 90 (3d Cir. 1984) (affirmative obligation to assist claimant in development of facts)
Reefer v. Barnhart, 326 F.3d 376 (3d Cir. 2003) (heightened duty to develop record for mental impairments)
Ransom v. Bowen, 844 F.2d 1326 (7th Cir. 1988) (greater entitlement to record development for mental illness)
Matthews v. Apfel, 239 F.3d 589 (3d Cir. 2001) (new evidence not presented to ALJ considered on remand; standard for evidence)
Plummer v. Apfel, 186 F.3d 422 (3d Cir. 1999) (RFC framework and burden-shifting at steps 4-5)
Monsour Med. Ctr. v. Heckler, 806 F.2d 117 (3d Cir. 1986) (substantial evidence standard and deferential review of ALJ decisions)
Brown v. Bowen, 845 F.2d 1211 (3d Cir. 1988) (concept of substantial evidence and deference to ALJ conclusions)