Hancock v. Astrue

Summary

The Fourth Circuit affirmed the denial of Karen Sue Hancock’s application for supplemental security income. The court held that substantial evidence supported the administrative law judge’s determination that Hancock did not satisfy Listing 12.05C for intellectual disability, including because the IQ scores were properly discounted and the record did not establish the required adaptive-functioning deficits or onset during the developmental period.

Holdings

1. An ALJ has discretion to assess the validity of an IQ-test result and is not required to accept the result merely because it is the only IQ score in the record.
2. The ALJ's rejection of Hancock's IQ scores was supported by substantial evidence because the examiner's omission regarding validity was coupled with evidence that the scores were inconsistent with Hancock's actual functioning and treating psychiatrists' notes.
3. Substantial evidence supported the ALJ's finding that Hancock failed to establish the required deficits in adaptive functioning and failed to establish that a qualifying deficiency manifested before age 22.
4. The ALJ's conclusion that Hancock was not disabled within the meaning of the Social Security Act was supported by substantial evidence, and the district court properly granted judgment on the pleadings for the Commissioner.

Questions Presented

1. Whether substantial evidence supported the ALJ's rejection of Hancock's IQ scores for purposes of Listing 12.05C.
2. Whether substantial evidence supported the ALJ's finding that Hancock failed to establish deficits in adaptive functioning initially manifested during the developmental period, as required by Listing 12.05C.
3. Whether the district court properly affirmed the Commissioner's denial of SSI benefits.

Disposition

affirmed