Rucci v. Commissioner of Social Security
1:23-cv-06911
E.D.N.YMar 11, 2025Background
- Steven R. sought judicial review after the Social Security Administration (SSA) denied his application for disability insurance benefits (DIB), alleging disability onset in March 2020 due to several physical impairments.
- His application was denied initially, on reconsideration, and by an Administrative Law Judge (ALJ) who found he could perform his past relevant work as a security guard based on his residual functional capacity (RFC).
- The ALJ concluded plaintiff had severe impairments (lumbar spine degenerative disc disease, foot drop, scoliosis, sinusitis, sleep apnea), but not chronic kidney disease.
- The Appeals Council declined review, making the ALJ's decision final.
- Plaintiff challenged the ALJ’s decision in federal court, raising errors in impairment severity findings and assessment of RFC.
- The court granted the SSA’s motion for judgment on the pleadings, affirming the denial of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ failed to find kidney disease severe | Kidney stones required regular treatment, surgery delay, hospitalization | No evidence kidney stones significantly limited basic work | ALJ supported by substantial evidence; not severe |
| ALJ RFC did not account for kidney stones | ALJ did not fully consider kidney stones in RFC assessment | ALJ considered kidney stones; plaintiff showed no related limitation | ALJ considered evidence, no RFC error |
| ALJ should have further restricted RFC | Evidence of foot drop, etc., warranted more than light work restriction | RFC aligned with most medical opinions; activities showed capacity | No error; substantial evidence for RFC |
| ALJ weighed Dr. Fernandez’s opinion wrongly | Should prioritize examiner's opinion over non-examiners | No hierarchy among sources; ALJ mostly credited opinion | ALJ properly evaluated persuasiveness |
Key Cases Cited
- Rucker v. Kijakazi, 48 F.4th 86 (2d Cir. 2022) (review of ALJ decisions requires checking for application of correct legal standard and substantial evidence)
- Schillo v. Kijakazi, 31 F.4th 64 (2d Cir. 2022) (substantial evidence is a deferential standard; court must uphold if evidence allows more than one rational interpretation)
- Colgan v. Kijakazi, 22 F.4th 353 (2d Cir. 2022) (court reviews ALJ findings for substantial evidence and correct legal standards)
- Estrella v. Berryhill, 925 F.3d 90 (2d Cir. 2019) (ALJs must explain determinations with specificity for court review)
- Rubin v. O’Malley, 116 F.4th 145 (2d Cir. 2024) (ALJ must address supportability and consistency in weighing medical opinions)