GUNTER v. COMMISSIONER OF SOCIAL SECURITY, 1:23-cv-01029-RBK

Plaintiff Taylor G. filed for Social Security Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI), alleging disability primarily due to mental and physical health conditions, including psychiatric disorders and knee osteoarthritis.
Plaintiff's claims were denied at the initial and reconsideration levels, and again after a hearing before an Administrative Law Judge (ALJ), whose denial became the final decision following an unsuccessful appeal to the Appeals Council.
Plaintiff timely appealed the ALJ’s decision to federal district court, challenging both the factual determinations and the application of governing legal standards.
The ALJ found plaintiff had several severe impairments (obesity, knee osteoarthritis, bipolar disorder, anxiety, and learning disorder), but not enough to meet or equal a listed disability.
The ALJ concluded plaintiff had the residual functional capacity (RFC) for modified light work with additional restrictions, and that sufficient jobs existed nationally for someone with her RFC, age, education, and experience.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ALJ’s consideration of non-severe impairments in RFC	ALJ failed to address certain medically determinable impairments in the RFC, constituting harmful error	Any omission was harmless because plaintiff didn’t show it would change the RFC outcome	Omission, if any, was harmless; no remand necessary
ALJ’s evaluation of plaintiff’s subjective complaints	ALJ improperly discounted the severity of plaintiff’s symptoms	ALJ gave proper, reasoned consideration to plaintiff’s complaints and explained finding	ALJ’s credibility analysis adequate and supported; deference required
Evaluation of Dr. Lazarus’s consultative report	ALJ erred by not evaluating the persuasiveness of the report, depriving court of meaningful review	ALJ not required to evaluate, and any error was harmless as report would not alter outcome	Failure to discuss persuasiveness was harmless; no remand
ALJ’s findings at step five regarding available jobs	ALJ’s vocational findings on education level, exertional limitations, and reasoning requirements were unsupported or inconsistent	ALJ’s findings were consistent, and vocational expert testimony provided substantial evidence	All vocational-related findings upheld; no inconsistency or prejudice shown

Knepp v. Apfel, 204 F.3d 78 (3d Cir. 2000) (substantial evidence standard for review of ALJ fact-findings)
Morales v. Apfel, 225 F.3d 310 (3d Cir. 2000) (defines "substantial evidence" for Social Security review)
Fargnoli v. Massanari, 247 F.3d 34 (3d Cir. 2001) (court cannot overturn agency decision if supported by substantial evidence)
Sykes v. Apfel, 228 F.3d 259 (3d Cir. 2000) (framework for judicial review of legal standards in Social Security cases)
Money v. Barnhart, 91 Fed. App’x 210 (3d Cir. 2004) (level 2 DOT reasoning jobs compatible with RFC limits to simple, routine work)