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Fillmore v. Colvin

Citation: 286 F. Supp. 3d 536Docket: 16–CV–6500L

Court: District Court, W.D. New York; December 12, 2017; Federal District Court

Narrative Opinion Summary

The case involves an appeal by the plaintiff against the denial of disability benefits by the Commissioner of Social Security under 42 U.S.C. 405(g). The plaintiff contested the decision of an Administrative Law Judge (ALJ), which was based on an evaluation of her severe impairments and residual functional capacity (RFC) to perform light work. The ALJ’s decision, following a five-step sequential evaluation, found that the plaintiff was not disabled under the Social Security Act. The ALJ considered medical evidence, including reports from treating physicians, and the plaintiff's own testimony about her daily activities. The plaintiff's appeal focused on the alleged improper handling of medical opinions, particularly a report by Dr. Whitbeck suggesting temporary disability. The court found that the ALJ properly assessed this report, which was not the most recent, and concluded that the plaintiff could perform light work. Additionally, the court supported the ALJ's credibility assessment of the plaintiff's symptom testimony. Ultimately, the court denied the plaintiff's motion for judgment on the pleadings, granted the Commissioner's cross-motion, and dismissed the complaint, affirming that the denial of benefits was supported by substantial evidence.

Legal Issues Addressed

Credibility Assessment of Claimant's Testimony

Application: The ALJ's assessment of the plaintiff's testimony about her symptoms was supported by substantial evidence, indicating partial incredibility.

Reasoning: The ALJ found the plaintiff's testimony regarding the intensity and persistence of her symptoms to be partially incredible, supported by medical evidence indicating good range of motion and reports of the plaintiff managing various household activities.

Five-Step Sequential Evaluation Process

Application: The ALJ applied this process to conclude that the plaintiff was not disabled, despite her severe impairments.

Reasoning: The ALJ used the five-step sequential evaluation process to assess Fillmore's claim. Key findings included her insured status, lack of substantial gainful activity since the onset date, and several severe impairments such as cervical fusions and knee degenerative joint disease.

Residual Functional Capacity (RFC) Assessment

Application: The ALJ determined the plaintiff's RFC did not include a 15-pound lifting restriction, based on medical evidence and conservative management of symptoms.

Reasoning: The ALJ concluded that Dr. Whitbeck believed the plaintiff could engage in some exertional work after a temporary recovery period, which was deemed appropriate.

Standard of Review under 42 U.S.C. 405(g)

Application: The court evaluated the ALJ's decision to determine if it was supported by substantial evidence and followed the correct legal standards.

Reasoning: The court upheld the ALJ's findings, emphasizing that the decision followed the correct evaluation process and was backed by substantial evidence.

Treatment of Medical Opinions

Application: The ALJ gave less weight to an earlier report of temporary disability from Dr. Whitbeck, finding it was not the most recent or controlling assessment.

Reasoning: The court found that this report was not the most recent assessment from Dr. Whitbeck, who later provided additional notes that did not reiterate the temporary disability claim.