Grantz v. Commissioner of Social Security Administration, 5:16-cv-02033

Plaintiff William L. Grantz applied for Period of Disability, DIB, and SSI; an ALJ denied benefits and the Appeals Council declined review.
Magistrate Judge Greenberg recommended affirming the Commissioner; Plaintiff objected only to the ALJ’s consideration of obesity under SSR 02-1p.
The district court conducted de novo review of the objection and limited review to the obesity issue because a blanket objection was improper.
The ALJ had found obesity a severe impairment, discussed it at Steps Two through Five, and relied on largely normal physical examination findings and physician opinions when assessing functional limitations.
Plaintiff argued the ALJ failed to consider obesity’s combined effects with other impairments; the Commissioner defended the ALJ’s evaluation as supported by the record.
The court concluded the ALJ’s analysis was supported by substantial evidence, adopted the magistrate judge’s Report, and affirmed the denial of benefits with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ properly considered obesity in combination with other impairments under SSR 02-1p	ALJ ignored combined effects of obesity and other impairments; normal exam findings were insufficient	ALJ considered obesity at each relevant step, cited exam findings and physician opinions, and reasonably concluded obesity did not add greater limitations	ALJ’s obesity analysis was supported by substantial evidence and affirmed
Whether record evidence required more restrictive RFC due to obesity	Plaintiff points to subjective complaints and some physician attributions to obesity	Commissioner: objective exams were largely normal and no treating source imposed greater restrictions	No treating/source opinion showing greater restrictions; ALJ’s RFC stands

Richardson v. Perales, 402 U.S. 389 (substantial evidence standard)
Mullen v. Bowen, 800 F.2d 535 (administrative decisions need only be supported by substantial evidence even if contrary evidence exists)
Shilo v. Comm’r of Soc. Sec., [citation="600 F. App'x 956"] (obesity must be considered in combination with other impairments)
Bledsoe v. Barnhart, [citation="165 F. App'x 408"] (SSR 02-1p does not mandate a particular mode of analysis for obesity)