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regulation

Related Cases

Hurst v. Commissioner of Social Sec., 522 Fed.Appx. 522

Facts

Joyce D. Hurst suffered a stroke on September 29, 2007, resulting in cardiac problems, mobility issues, pain, and psychological limitations. Medical evaluations indicated that she had low ejection fractions and migraine headaches, with a psychological evaluation revealing moderate limitations in several areas. The ALJ determined that Hurst had a severe combination of impairments but concluded that these did not meet the Social Security regulations' Listings. The ALJ assessed her residual functional capacity and found she could perform sedentary work with specific non-exertional limitations.

Hurst suffered a stroke on September 29, 2007, which led to cardiac problems, mobility and pain issues, and psychological limitations.

Issue

Did the ALJ properly consider all of Hurst's medical conditions in determining her residual functional capacity and the severity of her impairments?

Rule

The Social Security Administration applies a five-step sequential evaluation to determine if a claimant is disabled, which includes assessing the claimant's ability to engage in substantial gainful activity and whether they have a severe medically determinable impairment.

In order to determine whether a claimant is disabled, the Social Security Administration applies a five-step sequential evaluation.

Analysis

The court found that the ALJ adequately reviewed and addressed the medical opinions and records related to Hurst's low ejection fractions and migraine headaches. Although these symptoms were not explicitly listed as impairments, the ALJ's discussion and assignment of weight to the evidence indicated that he considered them in his determination. The ALJ's hypothetical question to the vocational expert included the ability to perform simple, routine tasks, which was deemed sufficient to account for Hurst's limitations in concentration, persistence, and pace.

Hurst's first two arguments are unavailing because the ALJ specifically reviewed and addressed the medical opinions and records of Dr. Sampong and Dr. Shanawany, which addressed Hurst's low ejection fractions and migraine headaches.

Conclusion

The court affirmed the ALJ's decision, concluding that substantial evidence supported the determination that Hurst was capable of performing sedentary work with certain limitations.

Finally, because the medical evidence showed that Hurst was capable of completing simple tasks and the ALJ's hypothetical to the VE specified that the individual was capable of simple, routine, repetitive tasks, the hypothetical 'sufficiently accounts' for Hurst's moderate limitation in maintaining concentration, persistence, and pace.

Who won?

The Commissioner of Social Security prevailed in the case because the court found that the ALJ's decision was supported by substantial evidence and that the ALJ had adequately considered Hurst's medical conditions.

The Commissioner of Social Security prevailed in the case because the court found that the ALJ's decision was supported by substantial evidence.

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