Greenwood v. Dudek
8:23-cv-01233
N.D.N.Y.Mar 11, 2025Background
- Plaintiff Courtney G. sought judicial review of the Social Security Commissioner’s denial of her applications for disability benefits (DIB and SSI) based on alleged impairments including mental health conditions and physical disorders.
- Plaintiff was born in 1990, had prior fast-food work experience, and cited a combination of gastrointestinal, neurological, and psychological conditions as disabling.
- Her applications were previously denied by an ALJ, the Appeals Council, and on remand after a court-ordered reversal, leading to the current review after a second adverse ALJ hearing.
- The ALJ found Plaintiff had several severe impairments but determined she did not meet or medically equal a listed impairment and retained the residual functional capacity (RFC) to perform medium work with some limitations.
- The ALJ discounted opinions from Plaintiff’s mental health counselors and a consultative psychiatrist, relying on other record evidence to find only moderate or mild functional limitations.
- The District Court reviewed whether the ALJ properly applied legal standards and whether the decision was supported by substantial evidence, as required under 42 U.S.C. § 405(g).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ's omission of idiopathic intracranial hypertension (IIH) as severe impairment | ALJ erred by not characterizing IIH as a severe impairment at Step Two and excluding related limitations from RFC | RFC captured all relevant symptoms via acknowledgment of plaintiff’s headaches; IIH caused no more than minimal limitations | ALJ adequately considered IIH by evaluating headache symptoms; omission was at most harmless error |
| Sufficiency of ALJ’s evaluation of medical opinions (LMHC Hanley, LMHC Southwick, Dr. Hartman) | ALJ improperly discounted supportive opinions without adequate justification | Opinions were unsupported, inconsistent with the record/activities, and providers were not acceptable medical sources | ALJ’s weighing of medical opinions was supported by substantial evidence and proper application of regulatory standards |
| Step Three Listings determination (12.04, 12.06, 12.15) | Plaintiff met or equaled the Listings due to marked/extreme limitations in mental functioning | Substantial evidence showed only mild-to-moderate functional limitations in all four paragraph B criteria | ALJ’s finding that Plaintiff did not meet the Listings was supported by substantial evidence |
| Consideration of Plaintiff’s subjective symptom testimony | ALJ erred by failing to credit Plaintiff’s statements about limitations and not complying with prior remand | ALJ properly considered objective evidence, activities, and inconsistencies as required by regulation | ALJ adequately and specifically supported the credibility determination; no legal error identified |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (definition of substantial evidence for review of administrative findings)
- Bowen v. Yuckert, 482 U.S. 137 (approving the five-step sequential evaluation for disability)
- Sullivan v. Zebley, 493 U.S. 521 (to meet a Listing, all criteria must be satisfied)
- Wagner v. Sec’y of Health & Human Servs., 906 F.2d 856 (scope of review of disability decisions under 42 U.S.C. § 405(g))
- Johnson v. Bowen, 817 F.2d 983 (court must ensure correct legal standards are applied)
- Valente v. Sec’y of Health & Human Servs., 733 F.2d 1037 (deference owed to Commissioner’s findings if supported by substantial evidence)