SHAFFER v. COMMISSIONER OF SOCIAL SECURITY
1:24-cv-06904
D.N.J.May 19, 2025Background
- Plaintiff, Robin S., applied for Social Security disability benefits alleging disability since July 2021 due to PTSD, adjustment disorder, chronic back injury, and visual impairment.
- Claims were denied initially and on reconsideration; a hearing was held before an ALJ, who also denied benefits.
- Plaintiff has a master’s in education and previously held multiple professional roles including vice principal and analyst.
- Medical records show chronic back pain (described as well-controlled with medication), mental health conditions (PTSD and anxiety), and vision issues (mild, best corrected to 20/30).
- Plaintiff’s functional limitations were assessed by both his treating physician (Dr. Baretto) and a state consulting psychologist (Dr. Umpierre), but both opinions were only partially credited by the ALJ.
- The ALJ concluded Plaintiff could perform his past relevant work as a telegraph service rater and was not disabled under the Social Security Act.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred by finding certain impairments non-severe | ALJ failed to properly consider vision loss, kidney stones, and acute stress | ALJ found these conditions non-severe or already accounted for in RFC | ALJ’s step two finding is supported by substantial evidence |
| Evaluation of medical opinions (Drs. Baretto & Umpierre) | ALJ’s explanations were cursory; did not adequately account for limitations | ALJ explained discounting based on inconsistency and activity level | ALJ gave sufficient, supported reasons; no reversible error |
| Consistency of RFC with past relevant work as rater | Past job’s demands conflict with RFC limits on social interaction, instructions | RFC is consistent with requirements of the job and VE testimony supports | No conflict; ALJ properly relied on VE and DOT for step four finding |
| Entitlement to direct award of benefits | Record shows Plaintiff is disabled; court should award benefits | Record does not conclusively establish disability | Request moot; no basis for direct award following affirmance |
Key Cases Cited
- Sykes v. Apfel, 228 F.3d 259 (3d Cir. 2000) (substantial evidence is the standard for reviewing ALJ factual findings in disability cases)
- Knepp v. Apfel, 204 F.3d 78 (3d Cir. 2000) (scope of judicial review of Social Security disability denials)
- Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (defining "substantial evidence" in administrative law context)
- Fargnoli v. Massanari, 247 F.3d 34 (3d Cir. 2001) (deference to ALJ factual findings under substantial evidence standard)
- Bowen v. Yuckert, 482 U.S. 137 (1987) (ALJ's role in identifying severe impairments at step two)
- Brown v. Astrue, 649 F.3d 193 (3d Cir. 2011) (ALJ’s role in resolving evidence conflicts and determining RFC)