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Wilson V Commissioner Of Social Security

                 UNITED STATES DISTRICT COURT                            
                    DISTRICT OF NEW JERSEY                               


KRISTIN W.,                                                              

          Plaintiff,                                                     
                                           No. 24-cv-08185               
     v.                                                                  
                                             OPINION                     
COMMISSIONER OF SOCIAL                                                   
SECURITY,                                                                

          Defendant.                                                     

APPEARANCES:                                                              
Adrienne Freya Jarvis                                                     
800 North Kings Highway, Suite 304                                        
Cherry Hill, NJ 08034                                                     

    On behalf of Plaintiff.                                              

Catherine Elisabeth Hamilton                                              
Shawn Cheree Carver                                                       
SOCIAL SECURITY ADMINISTRATION                                            
OFFICE OF PROGRAM LITIGATION                                              
6401 Security Boulevard                                                   
Baltimore, MD 21235                                                       

    On behalf of Defendant.                                              
O’HEARN, District Judge.                                                  
    This matter comes before the Court on Plaintiff Kristin W.’s1 (“Plaintiff”) appeal from a 
denial of Social Security disability benefits and supplemental security income by the Acting 
Commissioner of Social Security (“Commissioner”).2 (ECF No. 1). The Court did not hear oral 

argument pursuant to Local Rule 78.1. For the reasons that follow, the Court AFFIRMS the 
Commissioner’s decision.                                                  
 I.  BACKGROUND                                                          
    The Court recites herein only those facts necessary for its determination of this appeal.  
    A.  Administrative History                                           
    Plaintiff filed an application for a period of disability and Disability Insurance Benefits 
(“DIB”) on December 22, 2021, alleging an onset date of disability beginning September 10, 2018, 
due to a variety of physical and mental impairments including white matter disease, jaw surgery, 
arthritis, hearing loss, tinnitus, motion imbalance, depression, anxiety, ulcers, digestive issues, 
esophagitis, gastroesophageal reflux disease, hernias, kidney disease, temporomandibular joint 

disease (“TMJ”), migraines, and cholesterol. (AR 84–123, 228–41, 258). Plaintiff’s claims were 
denied initially on May 13, 2022, (AR 84–103), and upon reconsideration on August 18, 2022. 
(AR 104–23).                                                              

    1  Pursuant to this Court’s Standing Order 2021-10, this Opinion will refer to Plaintiff solely 
by first name and last initial.                                           
    2  The Court notes that Plaintiff’s counsel received four extensions to file the opening brief 
and one extension to file the reply. (ECF Nos. 8, 10, 12, 14, 19). The Court ordered that Plaintiff’s 
reply brief be filed by May 15, 2025. (ECF No. 19). Plaintiff filed her reply on May 19, 2025, 
without seeking leave of Court or providing any explanation for the delay. (ECF No. 20). In light 
of the repeated extensions and the absence of good cause, the Court exercises its discretion to 
disregard the reply brief. Green v. Rowan Univ., No. 22-00039, 2023 WL 3675956, at *3 (D.N.J. 
May 26, 2023) (citing Simpson v. City of Atl. City, No. 04-4537, 2007 WL 869528, at *1 (D.N.J. 
Mar. 20, 2007)). In any event, consideration of the reply brief would not alter the outcome. 
    On September 2, 2022, Plaintiff filed a Request for Hearing before an Administrative Law 
Judge (“ALJ”). (AR 151–152). A hearing was held on March 21, 2023. (AR 37–83). Plaintiff, who 
was represented by counsel, testified, as did a Vocational Expert (“VE”). (Id.). The ALJ issued a 
Decision Denial on August 30, 2023. (AR 14–36). Plaintiff sought review from the Appeals 

Council, which denied the request for review on June 7, 2024, making the ALJ’s decision the 
Commissioner’s final decision. (AR 1–6). Plaintiff timely filed this appeal on July 31, 2024, 
pursuant to 42 U.S.C. § 405(g) and 42 U.S.C. § 1383(c)(3). (ECF No. 1).   
    B.  Plaintiff’s Background and Testimony                             
    Plaintiff filed an application for DIB on December 22, 2021, alleging disability beginning 
September 10, 2018. (AR 228–41). She was 43 years old at the time of her alleged onset date and 
has a high school education. (AR 84–85). Plaintiff last worked in 2018 as a waitress at a diner, a 
position she held for approximately 11 years. (AR 44, 1598). She stopped working following a 
series of medical procedures, including lymph node and jaw surgeries. (AR 45–46). 
    At the March 21, 2023 administrative hearing, Plaintiff testified that she was unable to 

work due to a combination of physical and mental impairments, including bilateral carpal tunnel 
syndrome, left thumb arthritis, depression, and anxiety. (AR 47–49, 59). She described daily pain 
and numbness in both hands, worse on the left, and stated that she wore a wrist brace all day for 
left thumb arthritis. (AR 47). Plaintiff reported difficulty gripping and frequent dropping of 
objects, noting that her handwriting had become illegible. (AR 47–48). She testified that both 
hands were red, swollen, and painful at the time of the hearing. (AR 65). However, Plaintiff also 
testified that she had received injections in her hands for pain relief and wore a brace, which were 
helpful in alleviating some of her symptoms. (AR 47, 65).                 
    Regarding her mental health, Plaintiff testified that she suffered from lifelong depression 
and anxiety, including panic attacks and crying episodes. (AR 59). She had previously received 
therapy but had not seen a mental health provider since 2019, in part due to cost barriers. (AR 58, 
67). At the time of the hearing, she was taking only trazodone to aid with sleep. (AR 58). Plaintiff 

described difficulty concentrating, remembering appointments, and following through on tasks. 
(AR 55–56). Despite these limitations, Plaintiff testified that she was able to prepare simple meals, 
drive, perform light cleaning, care for pets, and engage in leisure activities like coloring and word 
searches. (AR 48, 55–57).                                                 
    C.  Medical History                                                  
    Plaintiff  has  been  evaluated  by  numerous  medical  providers  over  the  course  of  her 
disability claim and alleges disability based on a range of mental and physical impairments. (AR 
258). On appeal, however, Plaintiff primarily focuses on her claimed inability to work due to 
mental  limitations  related  to  her  difficulty  handling  stress  and  adapting  to  changes  in  the 
workplace, as well as manipulative limitations stemming from carpal tunnel syndrome and arthritis 

in her left thumb. The Court will briefly summarize the relevant medical evidence for purposes of 
this appeal. This recitation is not comprehensive.                        
    Plaintiff alleges disability due to anxiety and depression, with a history of substance use. 
She participated in residential detoxification and intensive outpatient treatment in early 2020. (AR 
375–750). During this period, she reported severe panic attacks, depressed mood, and poor sleep. 
Providers diagnosed major depressive disorder, generalized anxiety disorder, and substance use 
disorder. (AR 388).                                                       
    After her discharge in mid-2020, Plaintiff’s mental health treatment was limited. She 
resumed care with her primary physician, who monitored her condition and prescribed psychiatric 
medications. (AR 1520–1597). In April 2022, consultative examiner Dr. Theodore Brown assessed 
her as having moderately severe symptoms, including poor concentration, frequent crying spells, 
social  withdrawal,  and  stress-induced  hair-pulling.  (AR  1598–1601).  However,  he  did  not 
complete a functional assessment, and no treating provider opined that Plaintiff’s psychiatric 

conditions rendered her unable to work. State agency psychological consultants evaluated Plaintiff 
in May and July 2022. Both found that Plaintiff had moderate limitations in understanding, 
remembering, or applying information and concentrating, persisting, or maintaining pace but 
retained the ability to perform simple, routine work in a low-stress environment. (AR 89–90, 99–
100, 110–12, 120–22).                                                     
    Plaintiff also alleges limitations from bilateral carpal tunnel syndrome and left thumb 
arthritis. An EMG performed in 2021 confirmed mild bilateral carpal tunnel syndrome. (AR 2175, 
2216). X-rays showed mild to moderate arthritis in the left thumb. (AR 2415). Plaintiff was treated 
conservatively with splints and corticosteroid injections, which she testified were helpful. (AR 65, 
2176). Her providers observed some tenderness and positive provocative tests but otherwise 

normal range of motion and no muscle atrophy. (AR 2175). Notably, Plaintiff did not pursue 
additional treatment following a December 2022 visit and did not provide any physician opinions 
identifying functional restrictions related to her hands. (AR 88, 98, 110, 120).  
 II.  LEGAL STANDARD                                                     
    A.  Standard of Review                                               
    In reviewing applications for Social Security disability benefits, this Court has the authority 
to conduct a plenary review of legal issues decided by the ALJ. Knepp v. Apfel, 204 F.3d 78, 83 
(3d Cir. 2000) (citation omitted). In contrast, the Court reviews the ALJ’s factual findings to 
determine if they are supported by substantial evidence. Sykes v. Apfel, 228 F.3d 259, 262 (3d Cir. 
2000) (citations omitted); see also 42 U.S.C. §§ 405(g), 1383(c)(3). The United States Supreme 
Court has explained this standard as follows:                             
    Under the substantial-evidence standard, a court looks to an existing administrative 
    record and asks whether it contains sufficient evidence to support the agency’s 
    factual determinations. And whatever the meaning of substantial in other contexts, 
    the threshold for such evidentiary sufficiency is not high. Substantial evidence, this 
    Court has said, is more than a mere scintilla. It means—and means only—such 
    relevant evidence as a reasonable mind might accept as adequate to support a 
    conclusion.                                                          

Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (internal citations, quotation marks, and 
alteration omitted); see also Bailey v. Comm’r of Soc. Sec., 354 F. App’x 613, 616 (3d Cir. 2009). 
    The substantial evidence standard is a deferential standard, and an ALJ’s decision cannot 
be set aside merely because a Court “acting de novo might have reached a different conclusion.” 
Hunter Douglas, Inc. v. N.L.R.B., 804 F.2d 808, 812 (3d Cir. 1986) (citations omitted); see e.g., 
Fargnoli v. Massanari, 247 F.3d 34, 38 (3d Cir. 2001) (“Where the ALJ’s findings of fact are 
supported by substantial evidence, we are bound by those findings, even if we would have decided 
the factual inquiry differently.”) (citation omitted).                    
    Nevertheless, the Third Circuit cautions that this standard of review is not “a talismanic or 
self-executing formula for adjudication.” Kent v. Schweiker, 710 F.2d 110, 114 (3d Cir. 1983). 
“The search for substantial evidence is thus a qualitative exercise without which our review of 
social security disability cases ceases to be merely deferential and becomes instead a sham.” Id. 
The Court has a duty to “‘review the evidence in its totality,’ and ‘take into account whatever in 
the record fairly detracts from its weight.’” K.K. ex rel. K.S. v. Comm’r of Soc. Sec., No. 17-2309, 
2018 WL 1509091, at *4 (D.N.J. Mar. 27, 2018) (quoting Schonewolf v. Callahan, 972 F. Supp. 
277, 284 (D.N.J. 1997)). Evidence is not substantial if “it is overwhelmed by other evidence,” 
“really constitutes not evidence but mere conclusion,” or “ignores, or fails to resolve, a conflict 
created by countervailing evidence.” Wallace v. Sec’y of Health & Hum. Servs., 722 F.2d 1150, 
1153 (3d Cir. 1983) (citation omitted). Although an ALJ is not required “to use particular language 
or adhere to a particular format in conducting [the] analysis,” the decision must contain “sufficient 
development of the record and explanation of findings to permit meaningful review.” Jones v. 

Barnhart, 364 F.3d 501, 505 (3d Cir. 2004) (citation omitted).            
    B.  Sequential Evaluation Process                                    
    The Commissioner has promulgated a five-step, sequential analysis for evaluating a 
claimant’s disability, as outlined in 20 C.F.R. § 404.1520(a)(4)(i)–(v). The analysis proceeds as 
follows:                                                                  
    At step one, the ALJ determines whether the claimant is performing “substantial 
    gainful activity[.]” If he is, he is not disabled. Otherwise, the ALJ moves on to step 
    two.                                                                 

    At step two, the ALJ considers whether the claimant has any “severe medically 
    determinable  physical  or  mental  impairment”  that  meets  certain  regulatory 
    requirements.  A  “severe  impairment”  is  one  that  “significantly  limits  [the 
    claimant’s] physical or mental ability to do basic work activities[.]” If the claimant 
    lacks such an impairment, he is not disabled. If he has such an impairment, the ALJ 
    moves on to step three.                                              

    At step three, the ALJ decides “whether the claimant’s impairments meet or equal 
    the requirements of an impairment listed in the regulations[.]” If the claimant’s 
    impairments do, he is disabled. If they do not, the ALJ moves on to step four. 

    At  step  four,  the  ALJ  assesses  the  claimant’s  “residual  functional  capacity” 
    (“RFC”) and whether he can perform his “past relevant work.” A claimant’s “[RFC] 
    is the most [he] can still do despite [his] limitations.” If the claimant can perform 
    his past relevant work despite his limitations, he is not disabled. If he cannot, the 
    ALJ moves on to step five.                                           

    At step five, the ALJ examines whether the claimant “can make an adjustment to 
    other work[,]” considering his “[RFC,] . . . age, education, and work experience[.]” 
    That examination typically involves “one or more hypothetical questions posed by 
    the ALJ to [a] vocational expert.” If the claimant can make an adjustment to other 
    work, he is not disabled. If he cannot, he is disabled.              
Hess v. Comm’r of Soc. Sec., 931 F.3d 198, 201–02 (3d Cir. 2019) (internal citations and footnote 
omitted) (alterations in original).                                       
 III. ALJ DECISION                                                       
    At step one, the ALJ found that Plaintiff had not engaged in substantial gainful activity 

since her alleged onset date of September 10, 2018. (AR 20).              
    At step two, the ALJ determined that Plaintiff had the following severe impairments: 
generalized anxiety disorder, major depressive disorder, substance abuse disorder in remission, 
small vessel ischemic disease, and degenerative disc disease of the cervical and lumbar spine. (Id.). 
The ALJ also found that several of Plaintiff’s other impairments—including bilateral carpal tunnel 
syndrome, left thumb arthritis, migraines, hearing loss, chronic obstructive pulmonary disease, and 
TMJ dysfunction—were non-severe because they did not cause more than minimal work-related 
limitations. (AR 20–22). In particular, the ALJ noted that Plaintiff’s hand impairments were treated 
conservatively with splints and injections, yielded mild findings on diagnostic testing, and were 
not supported by ongoing treatment or any functional assessment identifying related limitations. 

(AR 21).                                                                  
    At step three, the ALJ found that none of Plaintiff’s impairments, individually or in 
combination, met or medically equaled the severity of any listing. (AR 22). Specifically, in 
evaluating the “paragraph B” criteria of the mental listings, the ALJ found that Plaintiff had 
moderate limitations in three broad areas—understanding, remembering, or applying information; 
concentrating, persisting, or maintaining pace; and adapting or managing oneself—and a mild 
limitation in interacting with others. (AR 23). The ALJ also found that the “paragraph C” criteria 
were not satisfied. (AR 24).                                              
    Before making the step four determination, the ALJ found that Plaintiff had the RFC to 
perform light work subject to the following limitations:                  
    [C]an occasionally climb, balance, stoop, kneel, crouch, and crawl. She can have 
    no concentrated exposure to extreme cold, heat, or humidity. She can have no 
    exposure to hazard such as machinery or heights. She can perform simple, routine, 
    and repetitive tasks. She can occasionally interact with supervisors and coworkers, 
    and never interact with the public.                                  
(AR 24). In formulating this RFC, the ALJ considered the entire record, including Plaintiff’s 
testimony, treatment history, and opinion evidence. The ALJ found that Plaintiff’s statements 
concerning the intensity, persistence, and limiting effects of her symptoms were not entirely 
consistent with the medical and other evidence of record. (AR 25–28). The ALJ noted that 
Plaintiff’s physical exams were generally benign, her treatment was conservative and intermittent, 
and no treating or examining source opined that she had work-preclusive limitations. (Id.). 
    The  ALJ  considered  the  opinions  of  the  state  agency  medical  and  psychological 
consultants, who opined that Plaintiff could perform a range of light, unskilled work with no 
manipulative limitations and only mild to moderate mental limitations. (AR 28; see also AR 84–
123). The ALJ found those opinions persuasive, noting their consistency with the record. (AR 28). 
Although both state agency psychological consultants noted that Plaintiff would benefit from a 
“low stress environment,” (AR 90, 100, 112), the ALJ did not expressly include that phrase in the 
RFC.  Instead,  the  ALJ  limited  Plaintiff  to  simple,  routine,  and  repetitive  tasks,  occasional 
interaction with supervisors and coworkers, and no interaction with the public. (AR 24).  
    At step four, the ALJ found that Plaintiff could no longer perform her past relevant work 
as a waitress. (AR 28–29). However, at step five, relying on the testimony of a vocational expert 
and considering Plaintiff’s age, education, work experience, and RFC, the ALJ found that Plaintiff 
could perform other work in the national economy. (AR 29). Specifically, the ALJ identified the 
representative occupations of mail clerk, routing clerk, and marker—each of which exists in 
significant numbers. (AR 30).                                             
    Accordingly, the ALJ concluded that Plaintiff was not disabled within the meaning of the 
Social Security Act from September 10, 2018, through the date of the decision. (AR 30). 

 IV. DISCUSSION                                                          
    In her appeal, Plaintiff asserts that the ALJ committed reversible error in two primary 
respects. First, Plaintiff contends that the ALJ erred in formulating the RFC by failing to properly 
incorporate  the  findings  of  the  state  agency  psychological  consultants—particularly  their 
assessment that she would require a “low stress environment”—and inadequately evaluated her 
testimony regarding anxiety, panic attacks, and difficulty with stress and routine changes.3 (Pl.’s 
Br., ECF No. 15 at 19, 23–25). Second, Plaintiff contends that the ALJ erred at step two and in 
formulating the RFC by failing to account for the limiting effects of her bilateral carpal tunnel 
syndrome and left thumb arthritis. (Id. at 19–23). She further argues that the ALJ improperly 
discounted her subjective complaints regarding hand pain, weakness, and reduced functionality. 

(Id. at 24–25). The Court finds Plaintiff’s arguments unpersuasive and, for the reasons that follow, 
affirms the decision of the ALJ.                                          
 A.  The ALJ Reasonably Accounted for Plaintiff’s Mental Health Impairments and 
    Adequately Addressed the State Agency Opinions and Symptom Testimony 



    3  To the extent Plaintiff argues that the ALJ erred by failing to account for her participation 
in a residential treatment program during the adjudicated period, (Pl.’s Br., ECF No. 15 at 18), the 
Court finds this argument to be undeveloped and therefore waived. See Conroy v. Leone, 316 F. 
App’x 140, 144 n.5 (3d Cir. 2009) (citation omitted) (the inclusion of only “one conclusory 
sentence” in an argument constitutes an “undeveloped argument [that] has been waived”). In any 
event, Plaintiff’s residential treatment addressed her substance abuse disorder, which cannot serve 
as the basis for disability. See 42 U.S.C. § 423(d)(2)(C).                
    Plaintiff argues that the ALJ erred by failing to include more restrictive limitations in the 
RFC related to her ability to adapt to stress, routine changes, and public interaction. Specifically, 
she contends that the ALJ improperly disregarded the state agency psychological consultants’ 
opinions that she would require a “low stress environment” and failed to explain her reasons for 

not incorporating that phrase into the RFC. (Id. at 19, 23–25). Plaintiff also challenges the ALJ’s 
evaluation of her symptom testimony regarding anxiety, panic attacks, and difficulty coping with 
changes and interpersonal interactions. (Id.).                            
    These arguments are unavailing because the RFC adequately accounted for Plaintiff’s 
moderate mental health limitations by restricting her to simple, routine, and repetitive tasks, 
occasional interaction with supervisors and coworkers, and no interaction with the public. (AR 24, 
26–28). These restrictions are functionally equivalent to a “low stress environment.” See Beth D. 
v. Kijakazi, No. 20-446, 2021 WL 4272849, at *9 (D.N.J. Sept. 21, 2021) (noting ALJ adopted 
RFC which defined low stress setting as “having only occasional changes in work setting4 and 
only occasional interaction with the public”); Noll v. Saul, No. 18-02145, 2020 WL 5249141, at 

*6 (M.D. Pa. Aug. 3, 2020), report and recommendation adopted in part, rejected in part, No. 18- 
02145, 2020 WL 5232405 (M.D. Pa. Sept. 2, 2020) (collecting cases with same definition); see 
also Menkes v. Astrue, 262 F. App’x 410, 412 (3d Cir. 2008) (“performing a ‘simple routine task’ 
typically involves low stress level work”).                               



    4  While the ALJ did not include only occasional changes in work setting in the RFC, the 
ALJ explicitly explained her rationale for not including this limitation, and the Court finds that 
this decision was supported by substantial evidence. (See AR 24 (“The record does not establish 
that the claimant has only marginal adjustment, that is, a minimal capacity to adapt to changes in 
the claimant’s environment or to demands that are not already part of the claimant’s daily life. 
There is no evidence that changes or increased demands have led to exacerbation of the claimant’s 
symptoms and signs and to deterioration in the claimant’s functioning.”)).  
    Additionally, both state agency psychological consultants opined that Plaintiff had only 
moderate limitations in concentration and persistence, and no significant limitation in responding 
appropriately to changes in the work setting. (AR 90, 100, 111, 121). The ALJ found these opinions 
persuasive and incorporated the substance of their recommendations into the RFC. (AR 28). 

Although Plaintiff emphasizes the consultants’ reference to a “low stress environment,” the ALJ 
was not required to use that language verbatim so long as the RFC reasonably captured the 
functional limitations described. See Miller v. Colvin, No. 13-1383, 2014 WL 4218622, at *6 
(W.D. Pa. Aug. 25, 2014) (upholding the ALJ's RFC finding despite the omission of low-stress 
because the RFC restricted Plaintiff to simple, routine, repetitive, and goal-oriented tasks with only 
occasional interaction with the public and co-workers and to an environment with only occasional 
changes in the work setting with no production rate pace).                
    Plaintiff also argues that the ALJ improperly rejected her testimony about the intensity, 
persistence, and limiting effects of her symptoms on the grounds that it was inconsistent with the 
record. She contends this analysis was necessarily flawed because the ALJ failed to properly 

address outcome-determinative medical opinion evidence and to account for limitations that are 
consistent with her self-described mental and manipulative impairments. (Pl.’s Br., ECF No. 15 at 
24–25). But the ALJ provided a thorough discussion of Plaintiff’s mental health history, noting 
her brief inpatient treatment in early 2020 and relatively limited care thereafter. (AR 26–28). The 
ALJ  acknowledged  Plaintiff’s  testimony  regarding  her  symptoms  but  concluded  that  her 
functioning had remained stable with medication and that her treatment history—limited to 
primary care visits and inconsistent medication use—did not support greater restrictions. (Id.). And 
there is substantial evidence in the record to support the ALJ’s conclusion. Indeed, no treating or 
examining provider opined that Plaintiff’s psychiatric symptoms precluded her from working or 
required more restrictive accommodations.                                 
    Ultimately, Plaintiff’s arguments amount to a disagreement as to how the ALJ weighed the 
evidence. But the ALJ’s findings are supported by substantial evidence in the record and thus 

entitled to deference. See Zirnsak v. Colvin, 777 F.3d 607, 610–11 (3d Cir. 2014). Because the 
ALJ reasonably evaluated Plaintiff’s mental impairments and provided a logical explanation for 
the limitations included in the RFC, remand is not warranted.             
 B.  The ALJ Did Not Err in Assessing Plaintiff’s Hand Impairments or in Omitting 
    Manipulative Limitations from the RFC                                

    Plaintiff argues that the ALJ erred at step two and in formulating the RFC by failing to 
account for limitations related to her bilateral carpal tunnel syndrome and left thumb arthritis. (Pl.’s 
Br., ECF No. 15 at 19–23). Specifically, Plaintiff contends that these impairments, while deemed 
non-severe by the ALJ, nonetheless imposed functional restrictions that should have been reflected 
in the RFC, particularly because all three jobs identified at step five require frequent handling and 
fingering. (Id.). Plaintiff also asserts that the ALJ failed to consider her self-described manipulative 
limitations. (Id. at 24–25).                                              
    The Court finds no error. As the ALJ concluded, the record supports the characterization 
of Plaintiff’s carpal tunnel syndrome as “mild” and her left thumb arthritis as “mild to moderate.” 
(AR  21,  2175–76,  2415).  Moreover,  Plaintiff’s  treatment  was  conservative  and  sporadic. 
Specifically, Plaintiff was treated with corticosteroid injections and prescribed wrist splints, which 
she testified helped alleviate her symptoms. (AR 47, 65, 2176, 2215, 2228, 2247). There is no 
evidence in the record of ongoing or escalating care. Indeed, after her December 2022 follow-up 
visit—at which her carpal tunnel was again described as mild, and her arthritis was described as 
mild to moderate—Plaintiff did not return for additional treatment. (AR 2175–76). 
    Plaintiff’s testimony regarding her hand symptoms is also inconsistent with the broader 
record. While she described difficulty gripping, dropping objects, and illegible handwriting, (AR 
47–48), she also reported that she could prepare simple meals, drive, care for pets, and engage in 
fine motor leisure activities such as coloring and completing puzzles. (AR 48, 55–57). The ALJ 

reasonably concluded that her ability to perform these activities undermined and was inconsistent 
with her allegations of disabling hand limitations. (AR 28). It is well established that an ALJ may 
discount subjective complaints that are inconsistent with objective medical findings and daily 
functioning. See 20 C.F.R. § 404.1529(c)(4); Salles v. Comm’r of Soc. Sec., 229 F. App’x 140, 
146–47 (3d Cir. 2007).                                                    
    In addition, just like her alleged mental health limitations discussed above, no medical 
source  opined  that  Plaintiff  had  work-related  manipulative  limitations.  The  state  agency 
consultants  who  reviewed  the  record  specifically  concluded  that  no  handling  or  fingering 
restrictions were warranted. (AR 88, 98, 110, 120). The ALJ found these opinions persuasive and 
consistent with the overall evidence of record, including the absence of clinical findings indicating 

sustained functional impairment. (AR 28). A mere diagnosis—without evidence of resulting 
functional limitation—is insufficient to warrant RFC restrictions. Phillips v. Barnhart, 91 F. App’x 
775, 780 (3d Cir. 2004).                                                  
    Plaintiff’s  contrary  argument  largely  invites  the  Court  to  reweigh  the  evidence  and 
substitute its judgment for the ALJ’s. But where, as here, the ALJ’s findings are supported by 
substantial evidence, they must be upheld. See Biestek, 587 U.S. at 103. Because the ALJ 
reasonably concluded that Plaintiff’s hand impairments did not cause functional limitations beyond 
those already incorporated in the RFC, remand is not warranted.           
                          CONCLUSION                                     
     For  the  foregoing  reasons,  the  Court  AFFIRMS  the  final  decision  of the  Acting 
Commissioner. An appropriate Order will follow. 

                                                HRISTINE P.  O7- HEARN 
                                               United States District  Judge 

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