Mental impairments insufficient to support finding of disability
Friday, April 3, 2020

Mental impairments insufficient to support finding of disability

By Payroll and Entitlements Editorial Staff

The claimant suffered from borderline intellectual functioning, learning delays, schizoaffective disorder, mood disorder, personality disorder, and an anxiety disorder, and applied for SSI benefits. After a hearing, the ALJ found that the claimant could perform his past relevant work as an unskilled material mixer. Alternatively, the ALJ found that there were significant numbers of jobs in the national economy that he could perform given his residual functional capacity (RFC). The Commissioner denied benefits and the district court affirmed the denial. The crux of the case, according to the appellate court, was at step three of the five-step process–specifically whether the claimant could meet listing 12.05(B), based upon an IQ of between 60 and 70, in addition to an extreme impairment in adaptive functioning or two marked limitations in adaptive functioning. The claimant argued that the ALJ did not actually consider intellectual disorder listing 12.05. In its review, the district court noted the ALJ’s failure to consider listing 12.05, but found that any error by the ALJ in not considering it was harmless, as the ALJ’s other findings made it clear that the ultimate finding that the claimant was not disabled was supported by substantial evidence in the record. The appellate court agreed, finding that there was insufficient evidence to support a finding that the claimant had significant deficits in adaptive functioning manifested by an extreme limitation in one area, or marked limitations in two areas as required. Moreover, he responded well to both medication and counseling. Finally, the claimant’s contention that the ALJ did not properly consider his mental limitations in describing his RFC was discounted where his therapist’s notes contradicted what was in the record. Benefits were denied (Keith Cronin v. Saul, CA-8, No. 18-3682, 12/27/2019).

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