CORONADO v. COMMISSIONER OF SOCIAL SECURITY
2:16-cv-01743
D.N.J.Aug 31, 2017Background
- Rosa Torres applied for Supplemental Security Income (SSI) on behalf of her son C.N.C., born 2010; application filed January 11, 2012, alleging speech and behavioral disabilities and asthma.
- Administrative proceedings: initial denials, hearing before ALJ Kimberly Schiro on March 18, 2014 (Spanish interpreter), ALJ denied benefits on July 29, 2014; Appeals Council denied review; plaintiff appealed to district court.
- ALJ found severe impairments: autism spectrum disorder with impulse control problems, mixed expressive language disorder, and asthma, but concluded Plaintiff does not meet or medically/ functionally equal a listed impairment.
- Functionally, ALJ rated domains: less-than-marked limitations in acquiring/using information, attending/completing tasks, caring for self, and health/physical well-being; marked limitation only in interacting/relating with others; no limitation in moving/manipulating objects.
- Plaintiff challenged the ALJ’s determinations in the domains of acquiring/using information and attending/completing tasks, arguing the record shows marked limitations; district court reviewed for substantial evidence.
- District court affirmed the Commissioner, finding the ALJ adequately considered and weighed the record, addressed conflicting evidence, and supported her domain findings with substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred in finding less-than-marked limitation in acquiring and using information | ALJ ignored or insufficiently explained how improvements reduced functional limitations; record supports marked limitation | ALJ relied on therapy progress notes, SLP report, and treatment records showing improvement and considered conflicting evidence | Court: ALJ provided adequate explanation and substantial evidence supports less-than-marked finding |
| Whether ALJ erred in finding less-than-marked limitation in attending and completing tasks | ALJ failed to account for Beckwith’s 2013–2014 treatment notes showing attention deficits and rapid task-switching | ALJ relied on evaluations of Drs. Chandrasekhar and Azaro, considered Beckwith’s letters and other records, and weighed providers’ opinions | Court: ALJ considered the records, explained weight given to opinions, and substantial evidence supports less-than-marked finding |
| Whether ALJ failed to address conflicting evidence and explain credibility/weighting | ALJ did not adequately discuss or weigh contradictory provider notes showing more severe deficits | ALJ discussed multiple providers, explained reasons for assigning weight (e.g., scope of record review, treatment relationship, purpose of forms) | Court: ALJ complied with Burnett/Jones standards; reasoning permits meaningful review |
| Whether impairments meet or medically equal listed impairments | Plaintiff asserts combination of autism, language disorder, and asthma functionally/equivalently meet listings | ALJ found listed criteria not met: asthma controlled, communication improved, not a markedly restricted repertoire | Court: ALJ’s listing analysis is supported by record and substantial evidence |
Key Cases Cited
- Hartranft v. Apfel, 181 F.3d 358 (3d Cir. 1999) (defines substantial evidence as relevant evidence a reasonable mind might accept)
- McCrea v. Commissioner of Social Security, 370 F.3d 357 (3d Cir. 2004) (substantial evidence need not be a preponderance)
- Burnett v. Commissioner of Social Security, 220 F.3d 112 (3d Cir. 2000) (ALJ must indicate evidence rejected and reasons to permit meaningful review)
- Jones v. Barnhart, 364 F.3d 501 (3d Cir. 2004) (Burnett does not mandate specific language or format; adequate explanation suffices)
- Cotter v. Harris, 642 F.2d 700 (3d Cir. 1981) (ALJ must provide clear and satisfactory explication of basis for decision)