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Trancynger v. Commissioner of Social Security

Citation: 269 F. Supp. 3d 106Docket: 16 Civ. 2153 (GWG)

Court: District Court, S.D. New York; September 5, 2017; Federal District Court

Narrative Opinion Summary

This case involves a claimant who sought judicial review after the denial of his disability insurance benefits application by the Social Security Administration (SSA). The claimant, a former police officer, alleged disability due to multiple impairments following a work-related injury. After the SSA denied his application, the claimant requested a hearing. The Administrative Law Judge (ALJ) conducted two hearings and ultimately determined that the claimant was not disabled under the Social Security Act. The ALJ's decision was based on the finding that, although the claimant had several severe impairments, none met the criteria of the listed impairments. The ALJ also concluded that the claimant retained the residual functional capacity to perform certain sedentary jobs available in the national economy, despite being unable to return to his previous police officer role. The claimant contested the ALJ’s findings, arguing errors in evaluating his impairments, the weight assigned to medical opinions, and the assessment of his residual functional capacity. The court, upon review, upheld the ALJ's decision, noting it was supported by substantial evidence and consistent with the applicable legal standards. Consequently, the court denied the claimant’s request for remand and granted the Commissioner’s motion for judgment on the pleadings, thereby affirming the denial of disability benefits.

Legal Issues Addressed

Credibility Assessment of Claimant

Application: The ALJ evaluates the claimant's credibility concerning their symptoms and must provide a rationale if dismissing their subjective complaints.

Reasoning: It is the Commissioner’s responsibility to resolve evidentiary conflicts and evaluate the credibility of witnesses, including the claimant.

Definition of Disability under the Social Security Act

Application: The claimant must demonstrate an inability to engage in substantial gainful activity due to a medically determinable physical or mental impairment expected to last for at least 12 months.

Reasoning: The Social Security Act defines "disability" as the inability to engage in substantial gainful activity due to a medically determinable physical or mental impairment expected to last for at least 12 months.

Duty to Develop the Record

Application: The ALJ is required to obtain a claimant's medical records and inquire sufficiently into their medical history unless the record is already complete.

Reasoning: The duty to develop the record in disability claims includes obtaining a claimant's medical records and adequately questioning the claimant.

Five-Step Process for Evaluating Disability Claims

Application: The Commissioner employs a sequential five-step process to evaluate disability claims, focusing on substantial gainful activity, severity of impairments, and residual functional capacity.

Reasoning: The Social Security Act regulations outline a five-step process for the Commissioner to evaluate disability claims, as detailed in 20 C.F.R. 404.1520.

Judicial Review under 42 U.S.C. § 405(g)

Application: The court's review of the Commissioner's final decision is limited to determining if it is supported by substantial evidence and adheres to correct legal standards.

Reasoning: Judicial review of the Commissioner of Social Security's final decisions under 42 U.S.C. § 405(g) is confined to assessing whether the conclusions are supported by substantial evidence in the record and adhere to correct legal standards.

Treating Source Rule

Application: The ALJ must give more weight to medical opinions from treating sources, providing 'good reasons' if these opinions are not given controlling weight.

Reasoning: The 'Treating Source' Rule mandates that an Administrative Law Judge (ALJ) must give more weight to medical opinions from a claimant's treating sources.