Facts

Plaintiff Ronald O., who was 46 at the time, sought judicial review of a final decision by Administrative Law Judge who denied Plaintiff's application for Supplemental Social Security Income. Plaintiff previously applied for SSI due to schizophrenia, anxiety, obsessive compulsive disorder, a heart attack, an enlarged liver, and 16 years of incarceration, but the ALJ determined Plaintiff was not disabled. Plaintiff then asserted causes of action for violations of Title XVI of the Social Security Act and challenged the ALJ's decision.

PLAINTIFF'S CONTENTIONS: Plaintiff contended Defendant ALJ erred when it improperly determined Plaintiff was not disabled and did not meet the 12-month disability durational requirement. Specifically, Plaintiff contended that since his disability onset date was January 1, 2014, the ALJ should have examined the duration of the symptoms from that date rather than the application date. Thus Plaintiff contended that Defendant ALJ erred in failing to consider evidence of Plaintiff's disability prior to the application date when it determined that Plaintiff's symptoms had not lasted for a continuous 12 month period. Plaintiff further contended the ALJ improperly considered the medical opinions of Dr. Salvador Arella, a treating physician, and Dr. Rashin D'Angelo, a consultative examiner. Specifically, Plaintiff contended that the ALJ improperly rejected Dr. Arella's and Dr. D'Angelo's opinions and failed to provide specific and legitimate reasons as to why he did so.

DEFENDANT'S CONTENTIONS: Defendant denied Plaintiff's contentions and moved for summary judgment on the basis that Plaintiff's alleged disability had improved with medication.

Result

The court ruled in favor of Defendant and affirmed the ALJ's decision after it concluded Plaintiff's treatment records showed that Dr. D'Angelo issued his opinion relatively early in Plaintiff's treatment and, his symptoms improved with medication.