Oliveira v. Commissioner of Social Security
1:23-cv-08551
E.D.N.YNov 7, 2024Background
- Plaintiff Shashi Oliveira applied for Supplemental Security Income (SSI) benefits, alleging disability due to lumbar disc disease as of May 19, 2020.
- The Social Security Administration (SSA) denied Oliveira's claim initially and on reconsideration; an Administrative Law Judge (ALJ) also denied the claim after a hearing.
- The ALJ found Oliveira had severe lumbar disc disease but retained the capacity to perform sedentary work with certain restrictions (e.g., use of a cane, no climbing ladders).
- The SSA Appeals Council denied Oliveira’s request for review, making the ALJ decision the final agency action.
- Oliveira challenged the ALJ’s decision in federal district court, raising issues about the sufficiency of the evidence and the assessment of her treating physician’s opinion.
- Both parties moved for judgment on the pleadings; the district court reviewed the agency’s decision under the substantial evidence standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ’s residual functional capacity (RFC) finding was supported by substantial evidence | Record lacks substantial evidence that Oliveira can perform sedentary work | ALJ's RFC is supported by entire record, including non-medical and medical evidence | ALJ’s RFC finding supported by substantial evidence |
| Whether the ALJ erred in evaluating Dr. Ravi’s medical opinion | ALJ improperly dismissed Dr. Ravi’s opinion as “vague” and should have further developed the record | ALJ properly found Dr. Ravi's opinion only partially persuasive; opinion regarding limitations was vague and not inconsistent with sedentary work | ALJ correctly assessed Dr. Ravi's medical opinion |
Key Cases Cited
- Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (clarifies the substantial evidence standard for review of administrative findings)
- Cage v. Comm’r of Soc. Sec., 692 F.3d 118 (2d Cir. 2012) (court cannot substitute its judgment for that of the ALJ in Social Security appeals)
- Burgess v. Astrue, 537 F.3d 117 (2d Cir. 2008) (district court may set aside the Commissioner’s determination only if unsupported by substantial evidence or based on legal error)
- Halloran v. Barnhart, 362 F.3d 28 (2d Cir. 2004) (factual findings of the Commissioner are final if supported by substantial evidence)
- Richardson v. Perales, 402 U.S. 389 (1971) (defines substantial evidence in the administrative context)