Brown v. Astrue

U.S. DISTRICT COURT
NORTHERN DISTRICT OF NEW YORK
Social Services Law

New York Law Journal

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Judge Gary Sharpe

Brown challenged the denial of Disability Insurance Benefits. The court reasoned that it was clear that the Administrative Law Judge ("ALJ") had undertaken a detailed credibility analysis, and that his reference to consistency with the residual functional capacity determination ("RFC"), to which Brown objected, was merely an indication that the RFC determination incorporated those findings. The court found that the ALJ had indeed considered the objective medical evidence, treatment notes from Brown's health care providers, her activities of daily living, medication and other treatment she had received for her symptoms. The court further reasoned that despite the ALJ's failure to explicitly mention Brown's work history prior to the motor vehicle accident in which she alleged that she had sustained her disabling impairments, the ALJ's credibility finding, which considered the record and appropriate factors, was amply supported. The court held that while Brown suffered traumatic brain injury and neck pain, the medical assessments and clinical findings demonstrated a mild overall presentation and significant improvement sufficient to support the ALJ's determination in this case. Thus, Brown's complaint was dismissed.

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