Paduani v. Colvin, 1:16-cv-02300

Angela Paduani applied for Title II SSD benefits with an alleged onset date of November 17, 1986 and a date last insured of December 31, 1992; application file opened in 1994 and the claim has a long administrative history with prior remands.
After the most recent remand, the ALJ found Paduani insured through 12/31/1992, not engaged in substantial gainful activity during the period, and suffering from severe impairments: right knee post-surgery, major depressive disorder, lumbar degenerative disc disease, personality disorder, and obesity.
The ALJ found the impairments did not meet or equal a Listing and gave Paduani an RFC for sedentary work with occasional postural limitations and no close public contact.
Mental-health opinions in the record were limited to two consultative sources: Dr. Alfred Jonas (record review) who found only a moderate restriction for work with the public, and Dr. Sharon Grand (examination) who diagnosed major depressive disorder with marked limitations.
The ALJ assigned some weight to Dr. Jonas and little weight to Dr. Grand, finding Dr. Grand’s conclusions unsupported and inconsistent with record evidence of Paduani’s daily activities and other diagnoses (dysthymia, personality disorder NOS).
A vocational expert testified that, given the RFC, jobs existed (e.g., addresser, sorter, stuffer); the ALJ relied on this testimony to find Paduani not disabled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight given to competing consultative mental-health opinions	ALJ erred by relying on Dr. Jonas and rejecting Dr. Grand’s findings of major depressive disorder and marked limitations	ALJ permissibly relied on Dr. Jonas because no treating opinion existed, Jonas was a psychiatrist and his opinion fit the record; Dr. Grand’s conclusions were unsupported	Court affirmed ALJ: substantial evidence supports assigning more weight to Dr. Jonas and discounting Dr. Grand
Mental RFC assessment adequacy	RFC should have included more restrictive mental limitations based on Dr. Grand	RFC properly reflected the record and limitations supported by Dr. Jonas and claimant’s activities	Court affirmed ALJ’s RFC findings as supported by the record
Reliance on vocational expert (VE) testimony	VE testimony unreliable because she used a computer program and job counts (esp. addresser) are overstated	VE need not provide exhaustive source detail; she identified data sources generally and other occupations remain available	Court held VE testimony was reliable and sufficient; even if addresser were excluded, other jobs exist
Standard of review/deference to Commissioner	N/A (challenge framed under record evaluation)	Commissioner’s factual findings get deference if supported by substantial evidence	Court applied substantial-evidence standard and affirmed the ALJ’s findings

Cage v. Comm'r of Social Sec., 692 F.3d 118 (2d Cir. 2012) (court defers to Commissioner’s weighing of conflicting evidence)
Clark v. Comm'r of Soc. Sec., 143 F.3d 115 (2d Cir. 1998) (same principle of administrative deference)
Rutherford v. Schweiker, 685 F.2d 60 (2d Cir. 1982) (substantial-evidence standard applies even if record could support contrary conclusion)
McIntyre v. Colvin, 758 F.3d 146 (2d Cir. 2014) (VE need not identify figures with exhaustive specificity if sources are generally identified)
Galiotti v. Astrue, [citation="266 F. App'x 66"] (2d Cir. 2008) (affirming reliance on VE testimony despite lack of detailed job-number breakdown)
Rosado v. Sullivan, 805 F. Supp. 147 (S.D.N.Y. 1992) (court’s limited role under substantial-evidence review)
Bavaro v. Astrue, [citation="413 F. App'x 382"] (2d Cir. 2011) (Commissioner need show only one job existing in national economy at step five)