Zamora v. Social Security Administration, 1:16-cv-00456

Zamora applied for Supplemental Security Income (protective date Feb 15, 2012); ALJ denied benefits after hearing and Appeals Council denied review, making the ALJ decision final.
ALJ found severe impairments: heroin and alcohol addiction, degenerative disc disease, PTSD, and antisocial personality disorder; no past relevant work.
RFC: light work with occasional balance, avoid hazards, and limited to occasional, superficial interaction with co-workers and simple decisions in a stable environment.
Two consultative psychiatric exams conflicted: Dr. Paula Hughson (6/4/2012) found moderate-to-marked limits with public and moderate limits with coworkers/supervisors; Dr. C. Nadig (6/7/2013) found milder limitations and rejected PTSD.
ALJ gave moderate weight to Hughson and great weight to Nadig, adopting limitations for only occasional social interaction but specified only coworkers in the written RFC.
Plaintiff argued the ALJ erred by failing to include limits on interaction with supervisors and the public; court considered whether any omission was harmful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ erred in RFC by not including Hughson’s limits on interaction with supervisors and public	ALJ failed to adopt moderate limitations on supervisors/public from Hughson, requiring remand	ALJ permissibly discounted portions of Hughson’s opinion in favor of Nadig; any omission is harmless because VE jobs require minimal people contact	Court: No reversible error — ALJ gave legitimate reasons to discount Hughson, and any omission was harmless because the jobs identified involve minimal public/supervisor interaction

Vigil v. Colvin, 805 F.3d 1199 (10th Cir. 2015) (standard of review: factual findings supported by substantial evidence and correct legal standards)
Mays v. Colvin, 739 F.3d 569 (10th Cir. 2014) (standard for review of ALJ decision)
Wall v. Astrue, 561 F.3d 1048 (10th Cir. 2009) (five-step sequential evaluation for disability)
Smith v. Colvin, 821 F.3d 1264 (10th Cir. 2016) (court will not reweigh evidence)
Keyes-Zachary v. Astrue, 695 F.3d 1156 (10th Cir. 2012) (deficiency in factual findings or legal standard warrants remand)
Chapo v. Astrue, 682 F.3d 1285 (10th Cir. 2012) (weighting of medical-source opinions)
Oldham v. Astrue, 509 F.3d 1254 (10th Cir. 2007) (ALJ need not discuss every regulatory factor if decision is sufficiently specific)
Allen v. Barnhart, 357 F.3d 1140 (10th Cir. 2004) (harmless-error standard for social-security administrative decisions)