Shamika T. v. Frank Bisignano

Summary

The court affirmed the Commissioner of Social Security’s denial of Plaintiff Shamika T.’s application for supplemental security income. It held that the Administrative Law Judge reasonably considered Plaintiff’s non-severe depressive disorder and mild mental-function limitations but was not required to include corresponding restrictions in the residual functional capacity assessment because substantial evidence supported no resulting work-related limitations. The court ordered that judgment be entered for the Commissioner.

Holdings

1. An ALJ must consider all impairments, including non-severe impairments, when assessing the RFC, but mild limitations from a non-severe impairment need not be included as RFC restrictions when the record does not support functional limitations.

Questions Presented

1. Whether the ALJ erred by failing to include mental restrictions in the RFC after finding mild mental limitations at step two.
2. Whether substantial evidence supported the ALJ's determination that Plaintiff's non-severe depressive disorder caused no functional limitations requiring inclusion in the RFC.

Disposition

affirmed