Goodnough v. Commissioner of Social Security
U.S. DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
Social Services Law
Judge Lawrence Kahn
Goodnough worked as a data entry clerk, bookkeeper, expediter, and store manager. She claimed disability due to scoliosis, as well as an injury to and ganglion cyst on her feet. An administrative law judge (ALJ) denied her claim. The Appeals Council denied review. The ALJ gave "slight weight" to a report by treating physician Varnum, a family practitioner whose treatment of Goodnough's scoliosis was limited to prescribing analgesics. Also, based on vocational expert Andrews' testimony, the ALJ found that despite exertion limits not allowing her to perform the full range of light work, Goodnough was not disabled and could work as a mail, counter or order clerk, or a surveillance system monitor. District court affirmed the denial of benefits. It was, at worst, harmless error that the ALJ's decision did not mention Goodnough's "persistent efforts to obtain pain relief." Noting the five-step evaluation process in deciding if an individual is disabled, the court found substantial evidence supported the finding that Goodnough had residual functional capacity to perform light work not requiring her to walk or stand for more than four hours in an eight-hour day, nor exposing her to temperature extremes or pulmonary irritants.