Hart v. Commissioner of Social Security, 1:24-cv-05431

Plaintiff William Henry H. applied for Disability Insurance Benefits under the Social Security Act in December 2019, alleging disability since December 2017.
His applications were denied initially and on reconsideration; two administrative hearings led to denial, and remand from federal court resulted in a new hearing.
On May 9, 2024, ALJ Ifeoma Iwuamadi denied the application, finding Plaintiff had severe impairments but retained residual functional capacity to do some light work with certain limitations.
Plaintiff was found unable to perform past work but deemed able to perform other jobs existing in significant numbers in the economy.
Plaintiff then filed this action seeking review, arguing the RFC finding inadequately addressed his need to avoid respiratory irritants due to asthma.
The court reviewed the administrative record, parties' briefs, and denied Plaintiff’s motion for judgment on the pleadings, upholding the Commissioner’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the ALJ’s residual functional capacity (RFC) finding regarding respiratory irritant exposure supported by substantial evidence?	RFC failed to sufficiently protect Plaintiff from exposure to respiratory irritants given his asthma and medical opinions recommending avoidance.	ALJ sufficiently accounted for Plaintiff’s asthma by limiting him only from concentrated exposure, as medical evidence and daily activities support.	Court held for Commissioner, finding substantial evidence supports ALJ’s determination—no need for broader limitation.

Melville v. Apfel, 198 F.3d 45 (2d Cir. 1999) (reviewing courts do not decide disability de novo, review is for substantial evidence)
Poupore v. Astrue, 566 F.3d 303 (2d Cir. 2009) (review limited to whether there is substantial evidence and correct legal standard applied)
Talavera v. Astrue, 697 F.3d 145 (2d Cir. 2012) (reviewing courts must consider entire record and contradictory evidence)
Lamay v. Commissioner of Soc. Sec., 562 F.3d 503 (2d Cir. 2009) (substantial evidence defined as relevant evidence a reasonable mind might accept)