Amy Lynch v. Commissioner Social Security

CourtCourt of Appeals for the Third Circuit
DecidedMay 17, 2024
Docket23-1982
StatusUnpublished

This text of Amy Lynch v. Commissioner Social Security (Amy Lynch v. Commissioner Social Security) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Amy Lynch v. Commissioner Social Security, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

________________

No. 23-1982 ________________

AMY S. LYNCH, Appellant

v.

COMMISSIONER SOCIAL SECURITY _____________

On Appeal from the United States District Court for the Middle District of Pennsylvania (D.C. Civil No. 3-22-cv-00023) District Judge: Honorable Joseph F. Saporito Jr. ________________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) on February 8, 2024

Before: HARDIMAN, SCIRICA, and RENDELL, Circuit Judges.

(Filed: May 17, 2024)

OPINION * ________________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. SCIRICA, Circuit Judge

Amy Lynch appeals the District Court’s order affirming the Commissioner of

Social Security’s denial of Lynch’s claims for disability insurance benefits and

supplemental security income under 42 U.S.C. §§ 405(g) and 1383(c)(3). The District

Court determined the Commissioner’s decision was supported by substantial evidence.

On appeal, Lynch contends the Commissioner did not properly weigh the medical

opinions and testimony in accordance with current regulations. We find the

Commissioner’s decision is supported by substantial evidence and will affirm.

I. 1

Lynch applied for Social Security disability insurance benefits and supplemental

security income in November 2019, having asserted a disability onset in December 2016.

App. 43. The Social Security Administration denied her application in July 2020 and

again in October 2020 upon reconsideration. Id. Lynch requested an administrative

hearing, which was held on March 30, 2021 via telephone in front of Administrative Law

Judge (“ALJ”) Randy Riley. Id. The ALJ heard testimony from Lynch, as well as a

vocational expert, and reviewed evidence from treating and non-treating medical sources.

Id. at 4. The ALJ found Lynch to have several severe impairments including depression,

generalized anxiety disorder, social anxiety, attention deficit hyperactivity disorder

(“ADHD”), and post-traumatic stress disorder (“PTSD”). Id. at 45. However, based on

Lynch’s own representations of her symptoms and an evaluation of the medical opinions

1 We write solely for the parties and so only briefly recite the essential facts.

2 in the record, the ALJ determined that, despite her impairments, Lynch has the residual

functional capacity (“RFC”) to perform “light work” as defined in 20 C.F.R. §

404.1567(b). App. 49. The ALJ determined Lynch’s categorization of the intensity,

persistence, and limiting effects of her symptoms was inconsistent with the medical

evidence in the record and found these symptoms resulted in only a moderate limitation

in her RFC. Id. at 50. Accordingly, the ALJ denied Lynch’s application for social

security income and disability benefits in a written decision dated April 28, 2021. Id. at

58.

Lynch sought the District Court’s review of the ALJ’s decision and timely filed a

complaint on January 5, 2022. Id. at 8. On March 31, 2023, the District Court upheld the

ALJ’s determination that Lynch was not disabled. Id. at 32. The District Court

determined the ALJ correctly applied the relevant law and that his decision was

supported by substantial evidence. Id. Lynch timely appealed. Id. at 39.

II. 2

We review the ALJ’s legal conclusions de novo. See Chandler v. Comm’r of Soc.

Sec., 667 F.3d 356, 359 (3d Cir. 2011). We review the ALJ’s factual findings for

“substantial evidence,” 42 U.S.C. § 405(g), which requires “more than a mere scintilla,”

such that “a reasonable mind might accept [it] as adequate to support a conclusion.”

Reefer v. Barnhart, 326 F.3d 376, 379 (3d Cir. 2003) (internal quotation marks omitted).

We do not weigh the evidence or substitute our own conclusions for those of the

2 The District Court had jurisdiction under 42 U.S.C. § 405(g). We have jurisdiction under 28 U.S.C. § 1291.

3 factfinder. See Williams v. Sullivan, 970 F.2d 1178, 1182 (3d Cir. 1992).

III.

The Social Security Administration has promulgated a five-step evaluation process

for ALJs to assess whether an individual qualifies as disabled. See 20 C.F.R. §

404.1520(a)(4). The first step requires the ALJ to assess whether the individual is

engaging in substantial gainful activity. Id. § 404.1520(a)(4)(i). At step two, the ALJ

assesses whether the applicant has a severe impairment or combination of impairments.

Id. § 404.1520(a)(4)(ii). At step three, the ALJ determines whether the impairment meets

the criteria of an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. Id.

§ 404.1520(a)(4)(iii). If the impairment does not meet these criteria, the ALJ moves to

step four and uses the applicant’s RFC—which is defined as the extent to which an

individual can still work despite limitations from the impairment—to determine whether

the applicant can still perform past relevant work. Id. § 404.1520(a)(4)(iv). If not, the

ALJ determines at step five whether the applicant has the ability to do other work

considering the RFC, age, education, and work experience of the applicant. Id.

§ 404.1520(a)(4)(v). The applicant bears the burden to establish steps one through four,

but at step five, the Social Security Administration must prove “the claimant is capable of

performing other jobs existing in significant numbers in the national economy.” Poulos v.

Comm’r of Soc. Sec., 474 F.3d 88, 92 (3d Cir. 2007).

To assess an applicant’s RFC, the ALJ has a “duty to hear and evaluate all relevant

evidence in order to determine whether an applicant is entitled to disability benefits.”

Cotter v. Harris, 642 F.2d 700, 704 (3d Cir. 1981); see 20 C.F.R. § 404.1520(a)(3).

4 Under regulations effective for claims filed after March 27, 2017, an ALJ must evaluate

the persuasiveness of all medical opinion evidence and prior administrative medical

findings based on five factors. See 20 C.F.R. § 404.1520c. The factors include: 1)

supportability, 2) consistency, 3) relationship with the claimant, 4) specialization, and 5)

other factors. Id. 3

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