98 F. Supp. 3d 614
W.D.N.Y.2015Background
- Plaintiff Wanda J. Williams filed for disability insurance benefits on September 23, 2010, alleging a disability onset date of December 1, 2009.
- ALJ John P. Costello issued a decision on June 29, 2012 finding Williams not disabled; the Appeals Council denied review on August 5, 2013, rendering the ALJ’s decision the Commissioner’s final decision.
- Plaintiff alleged mental health issues, diabetes, hypertension, carpal tunnel syndrome, and abdominal/ GI symptoms as disabilities.
- The Administrative Transcript details extensive medical history, including pre- and post-September 23, 2010 treatments for abdominal pain, diabetes, hypertension, carpal tunnel syndrome, and mood disorders.
- Plaintiff and Defendant filed cross-motions for judgment on the pleadings; the court grants the Commissioner’s motion and dismisses Williams’s complaint with prejudice.
- The court conducted a five-step sequential analysis, found at least one severe impairment, and upheld the RFC limiting Williams to medium work with specific nonexertional restrictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Step Two severity finding for carpal tunnel | Williams contends carpal tunnel is a severe impairment. | ALJ properly found other impairments severe and proceeded with the analysis; failure to label carpal tunnel as severe was harmless. | Harmless error; ALJ considered elbow/wrist pain in RFC and continued to step three. |
| Duty to develop the record regarding treatment | ALJ failed to request treating-source opinions and to fill gaps. | Record was robust; no obligation to obtain every file; no obvious gaps requiring remand. | No reversible error; substantial evidence supported RFC without treating-source opinion. |
| Weight given to medical opinions (Toor, Balderman, Hamilton, Jones) | ALJ erred by not weighing some opinions and by misapplying Jones’s input. | Some opinions pre-date the relevant period; Dr. Toor’s opinion was weighed and incorporated; Jones’s opinion supported RFC. | ALJ’s treatment of Dr. Toor and Dr. Jones supported by substantial evidence; no error. |
| Credibility assessment of Williams’s subjective complaints | ALJ failed to properly apply credibility standards and ignored extensive mental-health records. | Two-step credibility analysis properly applied; record showed inconsistent treatment adherence and objective findings. | Proper credibility analysis; no reversible error based on the evidence in the record. |
| Step Five and use of VE testimony | VE testimony supports availability of other work given RFC. | RFC and VE evidence together support finding of not disabled. |
Key Cases Cited
- Shaw v. Chater, 221 F.3d 126 (2d Cir. 2000) (five-step framework and substantial evidence standard applied in SSI cases)
- Frye ex rel. A.O. v. Astrue, 485 F. App’x 484 (2d Cir. 2012) (consulting opinions may constitute substantial evidence when consistent with record)
- Krach v. Comm’r of Soc. Sec., No. 3:13-CV-1089 (GTS/CFH), 2014 WL 5290368 (N.D.N.Y. 2014) (timeframe relevance; evidence prior to period not required to be considered)
- Diakogiannis v. Astrue, 975 F. Supp. 2d 299 (W.D. N.Y. 2013) (RFC limited to simple tasks consistent with evidence of concentration limits)
- Mongeur v. Heckler, 722 F.2d 1033 (2d Cir. 1983) (standard for reviewing disability determinations; substantial evidence)