Christopher Daniel Phillips V Frank Bisignano Commissioner Of Social

Key Facts

Issues

• The plaintiff challenged the ALJ's decision to partially reject his subjective testimony about the intensity and limiting effects of his symptoms, arguing the ALJ failed to provide clear and convincing reasons for doing so under the two-step credibility inquiry required by Garrison v. Colvin. The court examined whether the ALJ properly evaluated the plaintiff's descriptions of ongoing pain in his pelvis, jaw, and back, along with other symptoms including diarrhea, bowel movements, mobility limitations, and reliance on a walker. The ALJ found that while the impairments could reasonably cause these symptoms, the plaintiff's statements about their severity were not entirely consistent with the medical evidence and treatment history, noting poor compliance with prescribed treatment and lack of treatment for Crohn's disease and Raynaud's syndrome until mid-2024, six years after the alleged onset date.
• The plaintiff argued that the ALJ erred in finding his chronic lymphocytic leukemia did not meet the criteria for listing 13.05A2, which defines severe lymphoma as requiring initiation of more than one anticancer treatment regimen within twelve consecutive months. The ALJ determined the plaintiff's treatment with Ibrutinib constituted a single regimen throughout the disability period. The court found substantial evidence supported this finding, as the record demonstrated plaintiff had only one treatment regimen during the relevant period, and there was no indication the treatment regimen was changed to reflect more than one regimen within a consecutive twelve-month period, even though the treatment may not have caused remission.
• The plaintiff challenged the ALJ's step five determination, arguing it was flawed because the underlying RFC was defective for the reasons plaintiff argued. The court found the RFC was supported by substantial evidence and was not flawed in the manner plaintiff identifies, so there was no basis for plaintiff's argument that step five was consequently flawed. The court reviewed the record and concluded the ALJ's decision was supported by substantial evidence at each of the five steps of the required analysis, with the plaintiff providing no lawful basis for remand to the agency under 42 U.S.C. § 405(g).
• The plaintiff contended the ALJ failed to properly account for how his impairments combined to affect his residual functional capacity, specifically citing fecal incontinence from Crohn's disease, numbness and pain from Raynaud's syndrome, borderline auditory memory, limited mobility, and heart and respiratory failure requiring oxygen use. The court found the ALJ did address these impairments: gastric distress from Crohn's disease was considered with colonoscopy findings showing no remarkable findings; Raynaud's syndrome symptoms were addressed with the ALJ finding plaintiff could not tolerate extreme cold; auditory memory limitations were considered with the ALJ finding plaintiff could perform simple repetitive tasks; and oxygen use was accounted for with the ALJ noting plaintiff only requires occasional use.

Holdings

Remedies

Legal Principles

• The court applies the five-step sequential evaluation process for Social Security disability determinations. In steps one through four, the burden of proof is on the claimant to show they cannot engage in substantial gainful activity. At step five, the burden shifts to the Commissioner to show that other work exists in significant numbers in the national economy that the claimant can perform given their RFC, age, education, and work experience. The ALJ's RFC determination is a legal decision, not a medical opinion, and the court reviews the ALJ's decision under the substantial evidence standard, considering the entire record as a whole.
• The court reviews the Commissioner's decision under the substantial evidence standard, which is an extremely deferential standard requiring more than a scintilla but less than a preponderance. The court must find the Commissioner's decision conclusive if supported by substantial evidence—relevant evidence that a reasonable person might accept as adequate. The court considers the entire record as a whole and may not affirm simply by isolating specific supporting evidence. Even if the ALJ has erred, the Court may not reverse where the error is harmless, and the burden of showing an error is not harmless normally falls upon the party attacking the agency's determination.

Precedent Name

• Molina v. Astrue
• Tommasetti v. Astrue
• Lingenfelter v. Astrue
• Garrison v. Colvin
• Batson v. Comm'r of Soc. Sec. Admin.
• Biestek v. Berryhill
• Ford v. Saul
• Shinseki v. Sanders

Cited Statute

• Social Security Act
• Social Security Regulations

Judge Name

Passage Text

• After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) and 416.967(b) except he can occasionally balance, stoop, kneel, crouch, crawl, and climb ramps and stairs, he can never climb ladders, ropes, or scaffolds, he can never work at unprotected heights, he cannot tolerate any exposure to extreme cold, he can tolerate only occasional exposure to humidity, and he is limited to carrying out simple repetitive tasks.
• The totality of the ALJ's determination of plaintiff's RFC indicates that he aptly considered all medical evidence before him and properly relied on objective medical data, synthesizing and weighing it in light of the entire record. For the foregoing reasons, IT IS HEREBY ORDERED that: 1. Plaintiff's motion for summary judgment is denied; 2. Defendant's cross-motion for summary judgment is granted; 3. The Clerk of the Court shall enter judgment for defendant and close this case.
• The court must find the Commissioner's decision conclusive if it is supported by substantial evidence. Substantial evidence is relevant evidence which, considering the record as a whole, a reasonable person might accept as adequate to support a conclusion. Even if the ALJ has erred, the Court may not reverse the ALJ's decision where the error is harmless, and the burden of showing that an error is not harmless normally falls upon the party attacking the agency's determination.