Court: District Court, S.D. New York; May 8, 2015; Federal District Court
Kathy Jo Simmons filed for disability insurance benefits under Section 205(g) of the Social Security Act, claiming disability beginning June 1, 2007. After her application was denied, a de novo hearing was held before Administrative Law Judge (ALJ) Katherine Edgell on January 18, 2012, resulting in a decision that Simmons was not disabled. This decision became final after the Appeals Council denied her request for further review on May 31, 2013. Simmons, now represented by new counsel, initiated this action on August 7, 2013, seeking judicial review of the Commissioner's final decision.
Both parties consented to the jurisdiction of Magistrate Judge Frank Maas. The Commissioner filed a motion for judgment on the pleadings, asserting the ALJ's decision was legally sound and supported by substantial evidence. Simmons countered that the ALJ's residual functional capacity (RFC) determination, credibility assessment, and conclusion that she could perform past relevant work lacked substantial evidence.
During the hearing, Simmons, born in 1955, testified about her work history, including a recent role as a housekeeper and previous positions as a restaurant hostess and Avon seller. She claimed her inability to work was due to incontinence, neck stiffness, and back pain attributed to scoliosis, stemming from two automobile accidents in 2007 and 2008. Simmons described significant limitations, including severe neck pain restricting her movement and back pain preventing her from standing or sitting for extended periods. The motions for judgment on the pleadings were submitted without further briefing following the Commissioner’s reply memorandum on August 4, 2014.
Simmons experiences significant physical limitations, including bladder control issues, difficulty lifting items, numbness in her hands, and restricted overhead reaching. Daily activities such as making the bed, accessing kitchen cabinets, and cooking are affected, limiting her to light cleaning and reducing her ability to engage in her gift-basket-making business to just thirty minutes. Despite these challenges, she participates in community events, walks regularly, and performs home therapy exercises.
Following two automobile accidents in 2007 and 2008, Simmons received ongoing medical treatment. After the first accident in Alabama, she declined ambulance transport but went to the emergency room due to a mild neck injury and seat belt abrasion. Imaging studies, including MRIs of her cervical and lumbar spine, revealed degenerative changes, mild scoliosis, and no acute disc herniations. An orthopedic examination showed significant pain and limited movement in her lower back, while her cervical spine maintained nearly full range of motion. X-rays confirmed degenerative changes without fractures. Dr. Govindlala Bhanusali advised Simmons to refrain from work and prescribed medication.
On July 21, 2008, Dr. Bhanusali's follow-up examination of Simmons revealed similar findings to previous assessments. Simmons underwent chiropractic treatment from June 13, 2007, to January 8, 2008, and received eight weeks of physical therapy starting October 1, 2007. On June 18, 2007, Dr. Deborah Cassidy advised that Simmons would be unable to work until August 1, 2007, supporting her need for FMLA leave. On January 7, 2008, Dr. Christine Kmiec reported Simmons as partially disabled due to disk bulges and a restricted, painful range of motion in her cervical and lumbar spine. Following her first accident, Simmons consulted various physicians, including neurosurgeon Dr. Steven Jacobs on August 21, 2007. She reported neck and back pain, along with numbness in her hands. Dr. Jacobs noted decreased neck mobility and observed bulging discs and degenerative spondylosis in her cervical and lumbar spine based on previous MRIs. He ordered additional CT scans, which revealed moderate degenerative disc disease but no fractures or significant abnormalities, and confirmed benign findings during a follow-up on September 11, 2007. Dr. Raymond Hui diagnosed Simmons with costochondritis and Raynaud's syndrome on October 31, 2007, and subsequently noted high blood pressure. During a visit with physiatrist Dr. Valpet Sridaran on the same date, Simmons reported persistent headaches and neck pain, with guarded neck movements and tenderness in related muscle areas. Dr. Sridaran recommended trigger point injections for pain management, which Simmons declined. She returned for further evaluation on November 29, 2007.
Dr. Sridaran observed mild tenderness in Simmons' lower spinal region and paralumbar area, with voluntarily restricted flexion and extension. There was also mild weakness in neck flexors and extensors, and restricted passive range of motion. He diagnosed Simmons with cervical sprain, carpal tunnel syndrome, lumbosacral radiculopathy, and occipital neuralgia. During a follow-up on January 4, 2008, Simmons reported generalized body pain, fatigue, and sleeplessness, prompting Dr. Sridaran to note diffuse tenderness in the paravertebral muscles and possible fibromyalgia, concluding she had a temporary mild disability and could not perform heavy lifting.
On January 10, 2008, Simmons saw Dr. Sunitha Polepalle, a pain management specialist, for back, neck, and shoulder pain exacerbated by various activities. Examination revealed restricted neck movement and positive Phalen and Tinel signs in her right hand, while lateral leg rotation worsened her pain. Dr. Polepalle assessed myofascial pain, attributed back pain to lumbar facet dysfunction, noted upper extremity paresthesias, and observed aneurysmal dilation on cervical MRI, recommending trigger point injections.
Simmons had follow-up visits with Dr. Polepalle on February 16 and March 15, 2008, during which continued physical therapy and heat treatment were advised. An MRI of her left shoulder on June 3, 2008, indicated supraspinatus tendinopathy and mild degenerative changes consistent with impingement syndrome.
Following a second automobile accident on September 8, 2008, Simmons was admitted to Orange Regional Medical Center, primarily complaining of back pain. Examination showed mild tenderness in specific muscle areas but full cervical range of motion. She was discharged with a note allowing her to return to work without restrictions. On September 23, an MRI of the thoracic spine revealed dextroscoliosis without significant abnormalities. During a November 4 visit, Dr. Sridaran noted Simmons' complaints of pain in multiple areas, aggravated by strenuous activity, affecting her ability to perform household chores.
Dr. Sridaran observed that Simmons was anxious and her movements were guarded, with noted resistance in her passive neck motions and mild tenderness in her neck and right paracervical region. There was also tenderness in her right paralumbar muscles, resistance during straight leg movements, and painful restriction in right shoulder abduction, limited to thirty degrees. Although Simmons exhibited normal muscle tone, her rigidity made assessment difficult. Dr. Sridaran diagnosed her with cervical radiculitis, post-traumatic headache, right shoulder tendonitis, and sciatica, indicating a partial, temporary disability.
During a follow-up on December 29, 2008, Simmons reported increasing left shoulder pain, inability to raise her left arm, and chronic neck pain. Dr. Sridaran noted her distress, tenderness in the neck and suboccipital region, and positive tests indicating radicular symptoms and nerve compression. Swelling in her left forearm suggested edema, and there was significant paralumbar muscle tenderness. Dr. Sridaran's impression included the need to rule out cervical radiculopathy, occipital neuralgia, left shoulder rotator cuff syndrome, and carpal tunnel syndrome.
On January 19, 2009, Simmons visited Dr. Bhanusali, reporting pain and worsening numbness in her left shoulder and hand, alongside neck and lumbosacral pain. Tenderness was found in her left shoulder, cervical spine, and lumbosacral spine, with limited movement primarily in the lumbosacral area. Diagnostic tests revealed arthritis and calcification in the left shoulder, minimal subacromial bursitis, and a cervical MRI showed disc bulge and mild cord impingement. Dr. Bhanusali recommended modified work restrictions.
Simmons returned to Dr. Sridaran on February 10, 2009, where he noted her apprehension and guarded neck movements. Mild tenderness was still present, and he suggested her left-sided headaches might be due to post-traumatic cephalalgia. Overall, the assessments consistently highlighted Simmons' significant pain, restricted movement, and potential serious underlying conditions related to her injuries.
On March 30, 2009, Dr. Sridaran indicated that Simmons was on "temporary, moderate disability" but cleared her for full work status on May 1, 2009. Simmons subsequently consulted Dr. Neal Dunkelman, a rehabilitation specialist, on several occasions from August to December 2009, reporting tenderness in her shoulders and cervical back, along with restricted cervical range of motion. An MRI on August 19, 2009, showed cervical spine bulging at C5-C6 and C6-C7, with mild neural foraminal narrowing and a reversal of normal lordotic curvature. Shoulder MRIs indicated mild tendinosis without tears. Dr. Dunkelman diagnosed Simmons with cervical radiculopathy and bilateral shoulder sprain, stating she was unable to work and issued disability certificates from August to December 2009. In 2010, Simmons continued to experience neck and shoulder pain, prompting further visits to Dr. Dunkelman, who again confirmed her conditions and issued additional disability certificates. On July 27, 2010, Dr. Adam Carter examined Simmons, noting her mobility was minimally impaired despite decreased range of motion in her neck and lumbar spine, diagnosing her with traumatic cervical and lumbar pain syndromes and deeming her partially disabled due to injuries from car accidents. Follow-up appointments in August and September 2010 revealed ongoing pain but no significant changes in her condition. On November 16, 2010, Simmons began monthly visits with orthopedist Dr. Steven Weinstein.
Simmons reported neck, shoulder, and back pain, as well as difficulty sitting and standing. Dr. Weinstein's examination revealed full lumbar flexion with pain at the end range, full lumbar extension, and some neck limitation, particularly with cervical rotation. He noted decreased hand grip strength and sensation in both hands and the left lower extremity, but no atrophy or tenderness in the extremities. An MRI indicated broad-based disc bulges at C5-6 and C6-7, reversal of normal lordosis in the cervical spine, and left shoulder supraspinatus tendinosis. Dr. Weinstein diagnosed Simmons with a neck sprain, cervical disc degeneration, and rotator cuff syndrome, while also observing a degree of symptom amplification.
On May 25, 2011, Dr. Jeffrey Degen evaluated Simmons at Dr. Weinstein's request. He noted severe and constant mid-thoracic pain, radiating around the thorax, along with intermittent neck pain and chronic hand numbness. Although Simmons had a normal gait and range of motion in her extremities, she displayed "give way weakness." Radiological studies showed kyphosis at C5-6 without spinal cord compression, significant thoracic dextroscoliosis, and moderately severe lumbar scoliosis of thirty-three degrees. Dr. Degen linked her pain to thoracic scoliosis and referred her to a neurosurgeon for potential surgical intervention.
In connection with an earlier lawsuit from a 2007 accident, Dr. Michael Brooks reviewed an MRI of Simmons' cervical spine, concluding she suffered from multilevel cervical spondylosis and central disc herniation at C4-C5, exacerbated by chronic degenerative changes without signs of spinal cord or nerve root compression. Additionally, Dr. Steven Rocker conducted a consultative examination on April 28, 2008, noting Simmons' ability to perform daily activities and her normal physical capabilities, including specific ranges of motion in her cervical spine.
Dr. Rocker reported no scoliosis, kyphosis, or abnormalities in Simmons' thoracic spine, with full range of motion in her lumbar spine and extremities, described as stable and nontender. He found no motor or sensory deficits, muscle atrophy, and intact hand dexterity with grip strength rated at 5/5. A cervical spine x-ray showed mild anterolisthesis and disc thinning but no fractures or soft tissue swelling. Dr. Rocker diagnosed posttraumatic arthralgia/myalgia of the cervical spine and concluded Simmons had no limitations for sitting, handling, standing, or walking, but moderate limitations for lifting and carrying.
Dr. Paul Jones, upon examining Simmons at the request of Independent Physical Exam Referrals, noted limitations in cervical and shoulder motion, tenderness in the trapezius, and diagnosed cervical and lumbar syndrome with a guarded prognosis. He indicated Simmons had not returned to pre-injury activity levels, advised against lifting above shoulder height and bending, and was uncertain whether her right shoulder symptoms were due to neck issues or intrinsic shoulder problems.
Upon further evaluation on June 1, 2010, Dr. Jones documented limited shoulder flexion, normal grip strength, reflexes, and sensation, but tenderness in her cervical and trapezius areas. He noted restricted cervical motion and a positive straight leg raise test when supine. The right calf was one inch smaller than the left. Dr. Jones reaffirmed the connection of her injuries to two auto accidents, assessed her with marked disability, and stated she could only perform sedentary work with no lifting, bending, or reaching.
On March 26, 2009, Dr. Roberto Rivera conducted a consultative examination, where Simmons reported symptoms of Raynaud’s syndrome and persistent pain in her neck, back, shoulders, and wrists, along with paresthesia in her hands. She indicated she required help for daily activities, could cook with assistance, but found cleaning and laundry painful.
Simmons engaged in limited recreational activities, including listening to the radio, dining out occasionally, socializing, and collecting silk flowers. Physically, she experienced difficulty walking on her heels or toes due to balance issues and lower back pain, but could rise from a chair without assistance. Dr. Rivera's examination showed no spinal deformities, though Simmons had restricted lumbar spine extension, lateral flexion, and rotation due to pain. A cervical x-ray indicated reversal of cervical curvature and degenerative spondylosis at C5-C6 and C6-C7, without compression fractures. During straight leg raising tests, Simmons reported severe pain and achieved limited range of motion. Shoulder mobility was restricted, particularly on the left side, accompanied by severe pain. She also experienced numbness and tingling in her wrists, which affected her dorsi-flexion and palmar-flexion. Strength assessments revealed weakness in her upper and lower extremities, potentially influenced by volitional factors, with no trigger points present and normal deep tendon reflexes. Dexterity was intact, although grip strength was reduced, possibly due to volitional factors. While she could manipulate zippers and buttons, she struggled to tie due to perceived coldness in her hands. Dr. Rivera diagnosed her with possible Raynaud’s syndrome, high blood pressure, and chronic pain related to past car accidents. He concluded that her ability to sit, stand, walk, and reach remained unrestricted, while pushing, pulling, lifting, climbing, and bending were mildly to moderately restricted.
On February 22, 2011, Simmons underwent a pain management examination with Dr. Daniel Perri following her second auto accident. She reported various pain symptoms, including neck pain radiating to her right arm, tingling in her hands, back pain, and chronic shoulder pain, which worsened with certain movements. Dr. Perri's examination indicated mildly decreased range of motion in her cervical spine, tenderness in spinal regions, mild scoliosis, and decreased shoulder rotation. He noted Simmons demonstrated strength of at least four out of five in her upper extremities but did not exert full effort, while her lower extremities rated five out of five. Reflexes were symmetric, and there was no muscle atrophy observed. Dr. Perri diagnosed her with cervical spondylosis, lumbar spondylosis, and bilateral rotator cuff disease, stating these conditions preexisted but were exacerbated by the September 2008 accident. He restricted Simmons to lifting a maximum of twenty-five pounds and advised avoiding overhead lifting and repetitive movements, predicting the need for chronic treatment and possibly spinal injections.
On March 15, 2011, Dr. Jeffrey Nugent reviewed Simmons's records, concluding she could lift twenty pounds occasionally and ten pounds frequently, and could stand, walk, or sit for six to eight hours daily, with limitations on kneeling, crawling, and overhead reaching.
In her decision, ALJ Edgell found Simmons not disabled under the Act from June 1, 2007, to September 30, 2011, applying the five-step framework of 20 C.F.R. 416.1520 and 416.920. Simmons challenged the findings specifically at Step Four, where the ALJ determined her residual functional capacity (RFC) allowed for lifting/carrying up to twenty pounds occasionally and ten pounds frequently, with limitations on bending, twisting, and overhead work. The ALJ reasoned that the medical evidence did not substantiate the severity of Simmons’s complaints, noting that the MRI scans did not show acute pathology.
Simmons' claims of severe physical impairments, including herniation, nerve root impingement, and significant stenosis, were not supported by objective medical evidence, including x-rays and physical examinations. These evaluations showed no neurological abnormalities associated with her reported symptoms, such as numbness and pain, and demonstrated that Simmons had nearly full motion in her shoulder and cervical spine. The ALJ determined that Simmons' assertions of worsening conditions following a September 2008 auto accident were also unsubstantiated, as her mobility contradicts her claims.
During physical examinations, Simmons displayed nearly full range of motion, could perform a full squat without assistance, and had no issues with heel or toe walking, dressing, or transitioning between sitting and standing. The ALJ found that many of Simmons' exhibited restrictions were voluntary, noting her lack of effort during strength testing and refusal to engage in certain physical activities during consultative examinations.
Despite some physical findings such as tenderness and mild strength deficits, the ALJ credited expert opinions recommending limitations for Simmons, including restrictions on overhead lifting and moderate limitations for pushing, pulling, and climbing. However, the ALJ concluded that Simmons maintained intact reflexes, sensation, and full motor strength, with no significant neurological deficits corroborating her claims. Ultimately, the ALJ found no objective medical basis for debilitating conditions affecting Simmons' daily life or work capabilities, leading to the conclusion that she was not under a disability as defined by the Act and was capable of performing her previous jobs as a hostess and housekeeper.
Judgment on the pleadings under Rule 12(c) is appropriate when material facts are undisputed, allowing a party to obtain judgment as a matter of law based on pleadings. The Social Security Act states that the Commissioner’s findings are conclusive if supported by substantial evidence. Substantial evidence is defined as relevant evidence a reasonable mind might accept as adequate, not necessarily overwhelming. Courts do not review the Commissioner’s decisions de novo; they only verify the application of the correct legal standard and the presence of substantial evidence. An Administrative Law Judge’s factual findings can only be overturned if a reasonable factfinder would conclude otherwise.
Disability under the Act is defined as the inability to engage in any substantial gainful activity due to a medically determinable physical or mental impairment expected to last at least 12 months. For a claimant to be considered disabled, their impairments must prevent them from performing their previous work and limit their ability to engage in any other substantial gainful work, taking into account their age, education, and work experience. Impairments must be demonstrable through accepted medical techniques. The Commissioner follows a five-step sequential process to determine disability, starting with whether the claimant is engaged in substantial gainful activity and assessing the severity of any impairments along the way. If the claimant has an impairment listed in the regulations, they are considered disabled without regard to vocational factors.
The analysis of a claimant's disability status involves a five-step process. Initially, if the claimant does not have a listed impairment, the inquiry focuses on whether, despite any severe impairments, the claimant has the residual functional capacity (RFC) to perform past work. If the claimant cannot perform past work, the Commissioner assesses whether other work is possible. The burden of proof lies with the claimant for the first four steps, while the Commissioner must demonstrate capability for other work if the fifth step is reached. Key factors in determining disability include objective medical evidence, medical opinions based on this evidence, subjective reports of pain or disability from the claimant, and the claimant's educational background, age, and work experience.
The Administrative Law Judge (ALJ) has discretion in resolving conflicting medical opinions and must follow the five-step process but is not mandated to provide explicit reasoning for each step. However, their conclusions can still be upheld if supported by substantial evidence from other parts of the decision. At the fourth step, the ALJ evaluates whether the claimant's impairments hinder their ability to perform past relevant work, considering the consistency of symptoms with medical evidence. The RFC analysis must logically explain how symptoms, including pain, affect work capability. If the claimant retains the ability to perform past relevant work, they are deemed not disabled. The two-part inquiry at this step requires determining if there is a medically-determinable impairment that could reasonably produce the alleged pain or symptoms.
The ALJ must assess a claimant's credibility regarding symptom statements that lack objective medical evidence, determining how these symptoms affect the claimant's ability to perform basic work activities. Federal courts grant significant deference to the ALJ's credibility findings if supported by substantial evidence, particularly since the ALJ observes the claimant's testimony and demeanor firsthand.
The treating physician rule mandates that an ALJ give controlling weight to a treating physician’s opinion if it is well-supported and not inconsistent with other evidence. The Second Circuit emphasizes the unique position of treating physicians in forming accurate diagnoses due to their ongoing relationship with the patient. However, the ALJ is not required to accept a treating physician's opinion on disability, as this determination is solely the Commissioner's responsibility. A treating physician's claim of disability is not conclusive if contradicted by substantial evidence, which may include reports from consultative physicians. The Commissioner must provide "good reasons" for the weight assigned to a treating physician's opinion, and failure to do so or to apply the correct standards may necessitate a remand for further fact-finding.
In the case of Simmons, the ALJ's decision at Step Four regarding her residual functional capacity (RFC) concluded that she could lift/carry specified weights and sit, stand, and walk for limited periods. This conclusion was based on a review of the medical record, indicating that Simmons did not have a medically-determinable impairment to substantiate her claims of pain and limitations, which the ALJ found not entirely credible. Simmons challenges this decision, arguing that the ALJ improperly evaluated the medical evidence, assessed her credibility, and did not adequately consider her past relevant work.
Simmons challenges the ALJ’s evaluation of medical opinion evidence on two grounds. First, despite acknowledging that Dr. Perri was not a treating physician, Simmons argues the ALJ should have fully adopted Dr. Perri's recommendation for a complete restriction on overhead reaching, given the ALJ's assertion of affording Dr. Perri’s opinion “great evidentiary weight.” Second, Simmons claims the ALJ did not adequately consider the opinions of Drs. Jones and Bhanusali. Dr. Jones opined in October 2008 that Simmons could not return to her prior activity levels and should avoid lifting above shoulder level or more than ten pounds. Dr. Bhanusali, on February 3, 2009, recommended that Simmons be limited to modified work with a lifting restriction of no more than fifteen pounds.
The ALJ concluded that the job of restaurant hostess, as defined in the national economy, requires only light exertion and does not necessitate overhead lifting. Even if the ALJ erred by permitting some overhead lifting, the ultimate decision of “no disability” would remain unchanged. The ALJ’s partial rejection of Dr. Perri’s opinion does not necessitate a remand. Furthermore, while Dr. Bhanusali was the only treating physician, the ALJ reviewed Simmons’ medical history, noting consistent mild tenderness and a nearly full range of motion, ultimately concluding Simmons could lift up to ten pounds frequently and twenty pounds at most. This finding aligns closely with Dr. Bhanusali's lifting opinion. Dr. Jones’ opinions, while not from a treating physician, were also considered by the ALJ, who noted that Dr. Jones had previously stated Simmons could perform sedentary work with no lifting, bending, or reaching, which is similar to her earlier assessments.
Dr. Jones previously indicated that Simmons was limited to sedentary work, defined under 20 C.F.R. 404.1567(a) as involving lifting no more than 10 pounds. However, the ALJ rejected this assessment, citing it as inconsistent with the generally mild to moderate findings in Simmons' treatment records and his daily activities, supported by substantial evidence. Since Dr. Jones was not a treating physician, the ALJ was not obligated to defer to his opinion, and the weight assigned to it depended on its consistency with the record. The ALJ properly discounted Dr. Jones’ opinion due to its contradictions with other substantial evidence (citing Snell, 177 F.3d at 133).
Simmons challenged the ALJ's credibility determination, arguing that the finding that his subjective complaints were not fully credible lacked substantial evidence. The ALJ is required to conduct a credibility inquiry when a claimant's statements about symptoms are not substantiated by objective medical evidence (referencing Felix v. Astrue). While the ALJ must consider the claimant’s reports of pain, they are not obligated to accept them without question and may weigh credibility against other evidence. In assessing credibility, the ALJ considers factors such as daily activities, pain characteristics, medication effects, and other treatment measures. The ALJ is not required to address every factor as long as the decision is reasoned and supported by evidence, allowing them to make an independent judgment regarding the claimant’s alleged pain.
A plaintiff's subjective complaints of pain may be discounted if supported by substantial evidence, as established in *Martinez v. Astrue*. The ALJ found Simmons' claims about her pain severity not entirely credible, supported by various factors: absence of positive neurological findings, radiological studies revealing no significant issues, lack of muscle atrophy or sensory deficits, and Simmons' ability to perform daily activities, such as self-care and light cleaning. Although Simmons claimed extensive help from her husband, she acknowledged engaging in household tasks and community activities.
The ALJ noted signs of "symptom magnification" and "lack of effort" during examinations. Reports indicated that Simmons exhibited guarded behavior and voluntarily restricted her movements during assessments. Instances from several doctors documented her limited effort during physical tests, raising concerns about the authenticity of her claims. While Simmons argued that she restricted her movements to avoid pain, very few of her physicians attributed her limitations to a fear of pain. Additionally, discrepancies in her reports, such as claiming cold hands when they were warm, undermined her credibility. This collective evidence was deemed sufficient to uphold the ALJ's credibility determination regarding Simmons' pain complaints.
Simmons exhibited 4/5 strength in her upper extremities and 5/5 strength in her lower extremities, but did not exert full effort. The Secretary has the discretion to resolve evidentiary conflicts and assess witness credibility, including that of the claimant. The court's review focuses on whether the ALJ's determination that Simmons' claims of physical limitations were “not totally credible” is supported by substantial evidence, which the record provides abundantly, thereby upholding the ALJ's decision.
Regarding Simmons' ability to perform past relevant work, she argued that the ALJ failed to consider her duties as a hostess, specifically regarding overhead lifting. This argument was dismissed because the claimant bears the burden of proving an inability to return to past work. The ALJ determined Simmons could perform the role of a hostess, as defined in the Dictionary of Occupational Titles, which involves responsibilities such as supervising dining room staff, greeting guests, and ensuring service quality. The position is categorized as “light work” and does not necessitate significant overhead lifting. The ALJ concluded that Simmons was capable of performing this job as it is generally performed nationally, despite her challenges to the RFC indicating she could handle light work without overhead lifting. Even if her past role involved unusual overhead lifting, the ALJ's finding of “not disabled” was justified since the typical performance of the job does not require such tasks.
The RFC (Residual Functional Capacity) assessment for a claimant is generally adequate for concluding ‘not disabled’ based on the physical and mental demands of past jobs. Simmons' argument that her previous work as a hostess prevents her from returning to that job does not justify a remand to the Commissioner. The ALJ's decision is confirmed as legally sound and supported by substantial evidence. The Commissioner’s motion for judgment is granted, while Simmons’ cross-motion is denied, leading to the closure of the case. The document also includes definitions and explanations of various medical terms and conditions relevant to Simmons' case, such as spondylosis, sacralization, dextroscoliosis, and others, alongside references to regulations defining a "treating source" and the implications of medical opinions in the context of the claimant's abilities.
