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Stickney v. Commissioner of Social Security Administration, Not Reported in Fed. Supp., 2021 WL 3782835

Facts

Andrew Stickney filed an application for Title XVI disability benefits on May 12, 2016, claiming disability beginning January 4, 2002, which he later amended to January 10, 2009. The ALJ found that Stickney had severe impairments including obesity, bipolar disorder, generalized anxiety disorder, and obsessive-compulsive disorder, but was capable of medium work. The ALJ denied his request for benefits on August 27, 2019, and a request for reconsideration was also denied on June 25, 2020.

Petitioner filed an application for Title XVI disability benefits and Child Disability on May 12, 2016, alleging disability beginning January 4, 2002.

Issue

Did the ALJ err in rejecting the opinions of two physicians and the petitioner's symptom testimony?

Petitioner alleges the ALJ erred by improperly rejecting his treating physician's assessment, the examining physician's assessment, and his own testimony.

Rule

A person is considered 'disabled' under the Social Security Act if unable to engage in substantial gainful activity due to a medically determinable impairment expected to last for at least 12 months. The ALJ's decision should be upheld unless based on legal error or not supported by substantial evidence.

A person is considered 'disabled' for the purpose of receiving social security benefits if he is unable to 'engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.' 42 U.S.C. § 423(d)(1)(A).

Analysis

The court found that the ALJ properly evaluated the opinions of treating physician Dr. Benjamin and examining physician Dr. Yoches, determining that their assessments were inconsistent with the overall medical evidence and Stickney's own testimony. The ALJ provided specific and legitimate reasons for discounting these opinions, including evidence of Stickney's academic achievements and daily activities that suggested he was capable of work despite his impairments.

In reviewing Dr. Benjamin's opinions, treatment notes, Petitioner's activities, hobbies, and accomplishments, the Court finds the ALJ cited to substantial evidence showing Dr. Benjamin's opinions that Petitioner has severe social limitations and limited mental capabilities are not well-supported by the record.

Conclusion

The court affirmed the decision of the Commissioner of Social Security, concluding that the ALJ did not err in rejecting the medical opinions and the petitioner's testimony.

Therefore, the Court finds the ALJ did not err when he discounted Dr. Benjamin's opinion.

Who won?

The Commissioner of Social Security prevailed because the court found that the ALJ's decision was supported by substantial evidence and did not contain legal error.

Because the Court finds no legal error on the part of the ALJ, it will affirm the Social Security Administration's decision.

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