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Keywords

appealhearingadministrative lawjudicial reviewcredibility

appealhearingadministrative lawcredibility

Related Cases

Coffey v. Commissioner of Social Sec., Not Reported in F.Supp.3d, 2015 WL 5602945

Facts

Coffey filed an application for DIB on October 20, 2011, alleging disability since September 7, 2011. After his application was denied, he requested a hearing before an Administrative Law Judge (ALJ), which took place on October 17, 2012. The ALJ issued an unfavorable decision on November 7, 2012, which became the Commissioner's final determination after the Appeals Council denied review. Coffey subsequently filed a complaint seeking judicial review of this determination.

On October 20, 2011, Coffey filed an application for DIB under the Social Security Act (“the Act”), alleging disability since September 7, 2011. After his application was denied, Coffey requested a hearing before an Administrative Law Judge (ALJ), which was held on October 17, 2012. On November 7, 2012, the ALJ issued an unfavorable decision denying the requested benefits, which became the Commissioner's final determination upon the Social Security Administration Appeals Council's denial of review.

Issue

Did the ALJ err in determining Coffey's residual functional capacity (RFC) and in assessing his credibility?

Rule

The ALJ must consider all relevant medical and other evidence in assessing a claimant's RFC, and the RFC determination must be supported by substantial evidence in the record.

In assessing a claimant's RFC, an ALJ must consider 'all of the relevant medical and other evidence,' including a claimant's subjective complaints of pain. Id. § 404.1545(a)(3). An ALJ's RFC determination must be supported by substantial evidence in the record.

Analysis

The court found that the ALJ properly afforded significant weight to the opinions of Drs. Vilogi and Comrov, which supported the determination that Coffey could perform light work with certain limitations. The ALJ's decision was based on a thorough review of the medical evidence, including the findings of Coffey's treating orthopedic physician, Dr. Haher. The ALJ also conducted a detailed credibility assessment, considering Coffey's statements and activities, which were found to be inconsistent with his claims of disability.

The ALJ afforded significant weight to the opinions of Drs. Vilogi and Comrov in making his determination that Coffey could perform light work with a sit/stand option and postural limitations, despite his degenerative disc disease.

Conclusion

The court affirmed the Commissioner's decision, concluding that it was supported by substantial evidence and that the ALJ's determinations regarding Coffey's RFC and credibility were legally sound.

After careful review of the record, the court affirms the remainder of the ALJ's decision as it is supported by substantial evidence.

Who won?

Commissioner of Social Security; the court affirmed the Commissioner's decision, finding it supported by substantial evidence.

The Commissioner counters that the appropriate legal standards were used and the findings are supported by substantial evidence.

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