Wolkiewicz v. Commissioner of Social Security, 1:22-cv-00803

Plaintiff, Brenda W., applied for Social Security disability benefits, alleging disability beginning in July 2012, based on multiple physical impairments including obesity, edema, degenerative disc disease, and multiple sclerosis.
The case went through multiple administrative hearings and two prior remands from the District Court, with the latest ALJ decision in June 2022 again denying benefits for the claimed closed period.
The ALJ found plaintiff had severe impairments but did not meet a listed impairment; determined she retained the ability to perform sedentary work with specific limitations (including leg elevation and sit/stand requirements) prior to January 25, 2017.
Plaintiff moved for judgment on the pleadings, arguing the ALJ's residual functional capacity (RFC) was not supported by substantial evidence; the Commissioner cross-moved for judgment.
The District Court's review was focused on whether substantial evidence supported the ALJ’s highly specific RFC findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the ALJ’s RFC finding (especially leg elevation and sit/stand restrictions) supported by substantial evidence?	The ALJ imposed overly specific restrictions not directly supported by any medical expert evidence or the record.	The limitations were reasonable syntheses of the expert medical testimony, plaintiff's own statements, and the whole record, consistent with Second Circuit law.	RFC was supported by substantial evidence; no error.
Was it error for the ALJ to accept the vocational expert’s testimony over counter-evidence?	Vocational expert testimony was contradicted by plaintiff's submitted evidence; should not have been credited.	ALJ has discretion to resolve conflicts in expert testimony; agency’s fact-finding must be respected.	No error; ALJ properly weighed the evidence.
Did the ALJ properly account for plaintiff’s subjective complaints?	ALJ failed to fully credit plaintiff’s testimony about her impairments and functional limitations.	ALJ appropriately weighed subjective complaints against medical evidence and expert opinions.	No error; ALJ's weighing of subjective evidence upheld.
Should the case be remanded for further proceedings?	Remand is required due to alleged errors in RFC formulation and evidentiary weight.	Substantial evidence standard is met; no legal error warranting remand.	No remand; judgment entered for Commissioner.

Pratts v. Chater, 94 F.3d 34 (2d Cir. 1996) (sets deferential standard for reviewing Social Security disability findings)
Moran v. Astrue, 569 F.3d 108 (2d Cir. 2009) (discusses 'substantial evidence' standard for review of SSA decisions)
Brault v. Soc. Sec. Admin., Com'r, 683 F.3d 443 (2d Cir. 2012) (articulates highly deferential standard for judicial review of SSA fact-finding)
Clark v. Comm'r of Soc. Sec., 143 F.3d 115 (2d Cir. 1998) (court defers to agency's weighing of conflicting evidence)