PATRICIA S. HARRIS, Magistrate Judge.
Plaintiff Heather Knight ("Knight"), in her appeal of the final decision of the Commissioner of the Social Security Administration (defendant "Colvin") to deny her claim for Disability Insurance benefits (DIB) and supplemental security income (SSI), contends the Administrative Law Judge ("ALJ") erred by: (1) incorrectly assessing her residual functional capacity ("RFC"); and (2) not including Knight's morbid obesity in the hypothetical questions posed to the vocational expert. The parties have ably summarized the medical records and the testimony given at the administrative hearing conducted on March 20, 2014. (Tr. 30-49). The Court has carefully reviewed the record to determine whether there is substantial evidence in the administrative record to support Colvin's decision. 42 U.S.C. § 405(g).
Administrative hearing: Knight, who was 39 years old with a high school diploma, testified she was 5' 5" and weighed 362 pounds. She possessed a driver's license but stated she was anxious when driving. She drove herself to the administrative hearing. Knight had past relevant work as a factory worker and cashier
A vocational expert was asked several hypothetical questions by the ALJ. The expert testified Knight could not perform her past relevant work. Asked to assume a worker with Knight's numerous limitations
ALJ's Decision: In her September 12, 2014, decision, the ALJ found Knight had the following severe impairments: depressive disorder, anxiety disorder NOS, post traumatic stress disorder, borderline personality traits, history of cannabis abuse, morbid obesity, back disorder, hypertension and fibromyalgia. In considering Knight's mental impairments under "paragraph B" of the Listings, the ALJ determined Knight had mild restrictions in activities of daily living, moderate difficulties in social functioning and with regard to concentration, persistence or pace. The ALJ found Knight experienced no episodes of decompensation. The ALJ specifically noted the above limitations were not an RFC determination at Step 4 or 5 of the sequential evaluation, as RFC findings require more detailed analysis. The ALJ determined Knight's RFC precisely mirrored the limitations set forth in her hypothetical question to the vocational expert and found in footnote 2 herein. Relying upon the testimony of the vocational expert, the ALJ found Knight capable of performing work in the national economy, such as the job of surveillance monitor, and therefore not disabled. (Tr. 9-23).
First, the RFC conclusion is founded, to a large degree, upon the credibility assessment of the ALJ. Citing Polaski v. Heckler, 739 F.2d 1320 (8
The ALJ then addressed numerous Polaski factors to support her finding that Knight's subjective allegations were not fully credible. The ALJ noted Knight's possible non-compliance with her medications. (See Tr. 569). The ALJ also correctly noted no treating or examining physician opined she was disabled or imposed limitations greater than those described in the RFC. Further, Knight discontinued working for reasons other than her alleged disability (laid off due to seasonal nature of work), a factor which weighs against her credibility. In addition, there were inconsistencies in some aspects of the record. For example, Knight testified to a very limited ability to perform daily activities but came to the emergency room in July 2013 with wrist and leg pain "secondary to tripping and falling from a standing position while carrying some bricks." (Tr. 468).
The ALJ's assessment of Knight's credibility is supported by substantial evidence. This credibility finding laid the foundation for the ALJ's RFC determination, which included accommodations for Knight's physical impairments (limited to sedentary work, with significant other restrictions) and her mental impairments (limited to unskilled work, with significant other restrictions). Substantial evidence supports the RFC determination, and we find no merit in the first claim of Knight.
In addition, the ALJ thoroughly and correctly addressed the GAF scores in the record. These scores should not control when, as in this instance, the medical evidence is ample and entitled to greater weight. See Jones v. Astrue, 619 F.3d 963 (8
In summary, we find the ultimate decision of Colvin was supported by substantial evidence. We are mindful that the Court's task is not to review the record and arrive at an independent decision, nor is it to reverse if we find some evidence to support a different conclusion. The test is whether substantial evidence supports the ALJ's decision. See, e.g., Byes v. Astrue, 687 F.3d 913, 915 (8
IT IS THEREFORE ORDERED that the final decision of Colvin is affirmed and Knight's complaint is dismissed with prejudice.
IT IS SO ORDERED.