Bobby S.W. v. Dudek

Background

Bobby S.W. sought judicial review under 42 U.S.C. § 405(g) of the Social Security Commissioner’s final decision denying his applications for disability insurance benefits and supplemental security income. He alleged disability beginning July 15, 2020, based on bipolar disorder, obsessive-compulsive disorder, attention deficit disorder, back and ankle problems, obesity, and depression.

An administrative law judge, or ALJ, found that Bobby S.W. had severe impairments consisting of bipolar disorder, depressive disorder, morbid obesity, marijuana use disorder, and degenerative disc disease of the lumbar spine. The ALJ found that these impairments did not meet or medically equal a listed impairment. The ALJ assigned a residual functional capacity, or RFC, for light work with limits on standing, walking, lifting, climbing, postural activities, task complexity, pace, workplace interaction, and changes in work procedures.

The ALJ found that Bobby S.W. could perform his past work as a mailroom clerk. Alternatively, based on a vocational expert’s testimony, the ALJ found that he could perform other jobs existing in significant numbers in the national economy, including storage facility rental clerk, parking lot cashier, and credit clerk. The ALJ therefore found that he was not disabled, and the Appeals Council denied review.

Arguments on Review

Bobby S.W. challenged the decision on two grounds. First, he argued that the ALJ failed to consider the effects of his class III obesity at step three, when determining whether his impairments met or equaled a listed impairment, and at step four, when determining his RFC. He specifically argued that the ALJ should have addressed obesity’s effect on Listing 1.15 and on his mobility, lifting, reaching, workplace interaction, and ability to perform detailed tasks.

Second, Bobby S.W. argued that the ALJ failed to give a valid reason for rejecting his testimony about the severity of his symptoms. He contended that the decision was unsupported by substantial evidence and that the ALJ relied improperly on the lack of objective medical evidence.

Court’s Analysis

The court affirmed the step-three analysis. It explained that obesity is not itself a listed impairment, but obesity may contribute to medical equivalence when combined with another impairment. The claimant must still show medical findings equal in severity to all the criteria of the relevant listing. The court concluded that Bobby S.W. did not meet that burden for Listing 1.15. Although he testified that he sometimes used a walker when his calves hurt, he did not show that the walker was medically prescribed or establish the other required criteria.

The court also concluded that the ALJ adequately considered obesity in determining the RFC. The ALJ discussed obesity multiple times and relied on medical evidence showing normal gait, stance, grip strength, and motor strength; minimal degenerative changes; limited or no functional loss in several examinations; and medical opinions supporting light work with additional restrictions. The court stated that conflicting evidence did not justify reversal because the record contained enough evidence to support the ALJ’s findings.

The court upheld the ALJ’s evaluation of Bobby S.W.’s symptom testimony. The ALJ accepted that his impairments could cause the alleged symptoms but found that the claimed severity was not entirely consistent with the record. The ALJ relied on evidence including normal or reassuring physical examinations, effective treatment of back pain, the lack of prescribed medication for that pain, Bobby S.W.’s limited attendance at physical therapy, his activities of daily living, and medical opinions concerning his lifting ability. The court concluded that the ALJ gave multiple valid reasons, rather than relying only on the absence of objective medical evidence.

Disposition

The court denied Plaintiff’s Request for Relief, granted the Commissioner’s Request for Relief, affirmed the Commissioner’s Decision, and dismissed Bobby S.W.’s Complaint with prejudice. The order directed that judgment be entered accordingly.