Disability Appeal Examines Pain and Work Capacity Limits

Marie Ubaldini applied for Social Security disability insurance (SSDI) and supplemental security income (SSI) benefits, claiming she was unable to work due to injuries sustained in an accident. On October 31, 2015, she was struck by an SUV while riding her motorcycle, resulting in injuries to her left foot, fractured ribs, and a splenic laceration. Over the following years, she sought various treatments for ongoing pain, including physical therapy, pain management injections, a brace, and eventually, a surgical fusion in 2018 on several bones in her left foot. 

In 2018, Ubaldini formally applied for SSDI and SSI, claiming her injuries and pain prevented her from performing any substantial work activity. She alleged disability since the day of her accident and cited her chronic pain and reduced mobility as primary factors that impacted her ability to work. After the Social Security Administration (SSA) initially denied her claims, she requested a hearing before an Administrative Law Judge (ALJ) to appeal the decision.

ALJ Hearing and Evaluation Process

At the ALJ hearing, Ubaldini presented her case, emphasizing that her pain and limited mobility would prevent her from maintaining employment. She testified that even for sedentary jobs, her pain would be intolerable and that traveling to and from work would also be physically challenging. To support her claim, she provided medical records detailing her treatments, therapy sessions, and medications prescribed over the years. Despite these treatments, she testified that her pain persisted, and the 2018 foot surgery had not provided significant relief.

The ALJ conducted the standard five-step evaluation for determining disability under SSA guidelines. During the hearing, the ALJ reviewed Ubaldini’s medical history and received testimony from a vocational expert to evaluate potential job options based on her limitations. The vocational expert was asked to assess three hypothetical scenarios reflecting varying degrees of work limitations, including sedentary work restricted to simple and routine tasks.

Vocational Expert’s Testimony

Based on a hypothetical closely matching Ubaldini’s residual functional capacity (RFC) as assessed by the ALJ, the vocational expert testified that jobs existed within the national economy that Ubaldini could potentially perform, given her limitations. The expert’s testimony supported the position that some level of sedentary work could be feasible, despite her impairments.

After considering all evidence presented, the ALJ concluded that while Ubaldini’s medically determinable impairments could reasonably cause some of her symptoms, the evidence did not support a finding of total disability. The ALJ noted that medical examinations, including those from a consultative examiner, showed normal joint conditions, stable mobility with a cane, and the ability to move without assistance in certain activities. Additional evidence included reports of daily activities that demonstrated some functional capabilities, such as preparing simple meals, dressing, and socializing.

Ubaldini’s Alleged Limitations and Pain

Ubaldini argued that her pain and medication side effects interfered with her concentration and overall ability to function in a workplace. She contended that these limitations were consistent and disabling. However, the ALJ determined that the extent of her limitations was not fully corroborated by the medical evidence. The ALJ’s assessment emphasized that pain alone does not establish disability unless it is accompanied by objective medical findings that substantiate the severity of claimed limitations.

Following the ALJ’s decision, Ubaldini appealed to the United States District Court for the Eastern District of Pennsylvania, seeking a review of the ALJ’s findings. The District Court upheld the ALJ’s ruling, finding that the decision was supported by substantial evidence. Ubaldini then further appealed to the Third Circuit Court of Appeals.

The Third Circuit reviewed whether the ALJ’s findings were supported by “substantial evidence,” which requires relevant evidence that a reasonable person might accept as adequate. The court examined the records of medical assessments, the vocational expert’s testimony, and the ALJ’s analysis of Ubaldini’s functional abilities. It found that the ALJ had carefully weighed all available evidence, including the details of her treatment and her ability to perform certain daily activities.

Conclusion

After examining the arguments and evidence presented, the Third Circuit concluded that the ALJ’s decision was consistent with the standards of the Social Security Act. The court found that the ALJ had reasonably determined Ubaldini’s RFC and that sufficient jobs existed within her assessed limitations. This ruling underscores the need for objective medical evidence in establishing disability claims, especially when pain is the primary factor affecting a claimant’s work capacity.