Smith v Colvin

Smith appealed the rejection of her application for disability benefits. The panel affirmed. It held there was no harm in any error by the administrative law judge in not considering Smith’s left shoulder injury at step 2 of the 5 step analysis as he found sufficient disability to move to the remaining steps of the analysis. It held that the judge used the facts Smith wanted considered in the analysis and thus the examining doctor’s opinions were adequately discussed. It held there was no error in the judge’s decision to find some limitations on Smith’s use of her hands but not as significant a limitation as Smith wanted. It also held there was no error in not making explicit findings of fact about residual limitations as the judge used work activities which were limited to those activities consistent with the residual limitations. It finally held there was no need to apply limitations not present and held that Smith’s claims of factual error did not affect the outcome.