By: Katharine Yale
Today, in Jones v. Astrue, an unpublished opinion, the Fourth Circuit affirmed an Administrative Law Judge’s decision to deny Jones’ application for insurance disability benefits. The ALJ found that Jones’ hearing loss, knee pain, and foot problems did not render her disabled.
Substantial Evidence is the Standard of Review for the ALJ’s Denial.
In reviewing the ALJ’s conclusion, the Fourth Circuit was limited to evaluating whether the correct law was applied, and whether the ALJ’s findings were supported by substantial evidence. Evidence is substantial when a reasonable mind might accept the relevant evidence as adequate to support the conclusion. In the case that there is conflicting evidence, the reviewing court will defer to the ALJ’s conclusion, if the conflicting evidence would allow reasonable minds to differ.
The ALJ’s Decision to Deny Jones’ Disability Application Was Supported By Substantial Evidence.
The Fourth Circuit found that the ALJ correctly gave less weight to the opinions of Audiologist Fowler and Dr. Redmond. The two opinions were inconsistent with other substantial evidence such as Jones’ ability to perform everyday activities and communicate effectively at the hearings.
Additionally, the Fourth Circuit found that the ALJ was correct in not fully crediting Jones’ testimony regarding her impairment. Jones was able to communicate effectively at the hearing in front of the ALJ, and described her daily activities in a way that lessened the effect of her testimony regarding her impairment. This evidence supported the ALJ’s decision to give the testimony less credit.
Jones’ remaining two arguments were not raised at the district court and therefore could not be considered on appeal. The Fourth Circuit found, to the extent that Jones challenged the ALJ’s conclusion that her knee pain was not sufficiently severe, that the conclusion was supported by substantial evidence. Even though Jones reported pain, the evidence presented showed that she pulled her knee while working out, and that the injury did not present a disabling condition.
The Fourth Circuit Affirmed the ALJ’s Decision to Deny Jones’ Application for Disability Benefits.