Williams v. Social Security Administration, 2:24-cv-00120

Scott Williams applied for Disability Insurance Benefits and Supplemental Security Income, alleging disability due to anxiety, depression, substance use disorder, and ADHD, with an onset date of April 1, 2020.
The Social Security Administration denied his claim initially and upon reconsideration; an ALJ hearing in June 2023 resulted in an unfavorable decision, finding Williams not disabled at Step 5 of the Sequential Evaluation Process.
The ALJ found severe impairments but concluded Williams did not meet or medically equal a listed impairment, particularly under Listing 12.06 for anxiety and obsessive-compulsive disorders.
The ALJ assessed the Residual Functional Capacity (RFC), concluding Williams could do simple, routine work with limitations on interaction and work pace, and based on a vocational expert's testimony, found significant jobs available in the national economy.
Williams objected to the Magistrate Judge’s Report and Recommendation affirming the Commissioner’s denial, specifically arguing errors at Steps 3 and 5 of the evaluation process.
The District Court conducted a de novo review of the objected-to portions and ultimately denied Williams' objections, affirming the agency’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Step 3: Listing 12.06 Medical Equivalence	ALJ’s conclusion was boilerplate and failed to specifically articulate why Williams did not meet or equal Listing 12.06; SSR 17-2p is unlawful (post-Loper Bright)	SSR 17-2p allows a general statement if the later reasoning supports the finding; ALJ’s analysis met requirements	No reversible error; ALJ’s analysis and SSR 17-2p sufficient
Step 5: Hypothetical to Vocational Expert (VE)	ALJ failed to include all acknowledged limitations in the hypothetical, especially moderate limitations	ALJ incorporated all relevant limitations from the RFC into the hypotheticals to the VE	No reversible error; hypotheticals reflected RFC
Standard for Review and Court Authority	ALJ failed to follow new standards under recent case law (Loper Bright) and must articulate all findings more specifically	Agency’s regulations and analytical framework remain valid post-Loper Bright; agency findings supported by substantial evidence	No change in standard; agency acted lawfully and findings supported
Definition of "Moderate Limitation"	Magistrate Judge used inaccurate definition of moderate limitation, prejudicing the review	Definition in decision matches regulatory and circuit descriptions	Correct definition used and no error found

Richardson v. Perales, 402 U.S. 389 (standards for substantial evidence in disability review)
Shinseki v. Sanders, 556 U.S. 396 (administrative error must affect substantial rights)
Fraga v. Bowen, 810 F.2d 1296 (agency can rely on vocational expert testimony at Step 5)
Castllo v. Barnhart, [citation="151 F. App'x 334"] (ALJ not required to discuss every piece of evidence)
Ripley v. Chater, 67 F.3d 552 (review standard for substantial evidence in disability cases)