VILLANUEVA v. ASTRUE
2:11-cv-05344
E.D. Pa.Sep 4, 2012Background
- Villanueva, born October 2, 1953, alleged disability due to back/knee pain, numbness, and depression.
- She filed for SSI on October 31, 2008, asserting disability since December 1, 2000.
- Initial SSI denial followed by de novo review before an ALJ.
- Hearing held June 15, 2010; Villanueva amended disability date to April 24, 2009 after a motor vehicle accident.
- ALJ found severe impairments: degenerative cervical and lumbar spine disease and major depressive disorder; carpal tunnel not severe.
- ALJ concluded Villanueva could perform light work and could return to her past work as a press operator; Appeals Council denied review; Magistrate Judge Hart issued a Report and Recommendation denying Villanueva’s Request for Review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether carpal tunnel syndrome was properly deemed non-severe. | Villanueva argues carpal tunnel is a severe impairment. | Defendant contends evidence does not establish a compensable manipulative limitation. | Carpal tunnel not clearly shown as severe; ALJ’s ruling supported by substantial evidence. |
| Whether a manipulative limitation should have been included in the RFC/hypothetical to the VE. | Alleged need for limitations in reaching/handling/fingering. | Evidence insufficient to require such limitations; ALJ properly weighed medical evidence. | No reversible error; evidence not strong enough to require a manipulative limitation. |
| Whether Grid Rule 202.02 applies to Villanueva given age, education, and lack of transferable skills. | Rule 202.02 mandates disability if criteria met. | Grid applicability does not override ability to perform past work. | Grid rule alone not controlling because ALJ found past work available; not disabled under grids. |
| Whether the ALJ properly weighed the evidence on light-work capacity given objective findings and conservative treatment. | Back/neck conditions and pain limit work capacity beyond light work. | ALJ reasonably weighed conservative treatment and inconsistencies in subjective reports. | ALJ’s light-work finding supported by substantial evidence. |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (1971) (substantial evidence standard in SSA review)
- Doak v. Heckler, 790 F.2d 26 (3d Cir. 1986) (factors for substantial evidence review)
- Newhouse v. Heckler, 753 F.2d 283 (3d Cir. 1985) (substantial evidence standard governs reversal/remand)
- Coria v. Heckler, 750 F.2d 245 (3d Cir. 1984) (proper legal standards application in review)
- Hartranft v. Apfel, 181 F.3d 358 (3d Cir. 1999) (role of ALJ; avoid remand where substantial evidence supports decision)
- Monsour Medical Center v. Heckler, 806 F.2d 1185 (3d Cir. 1986) (substantial evidence and deferential review)