A.M. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Colorado reviewed the denial of A.M.'s claim for Social Security Disability Insurance benefits. The court held that the Administrative Law Judge adequately connected the migraine evidence to the residual functional capacity assessment, properly omitted unsupported computer-use, absence, and off-task limitations, and posed a proper vocational-expert hypothetical. The court affirmed the Commissioner's decision and directed the Clerk to enter judgment for the Defendant.

Holdings

1. The ALJ adequately explained the relationship between the migraine evidence and the RFC because the decision, read as a whole, discussed the migraine treatment history, frequency, listing analysis, and the added workplace noise restriction.
2. The omission of an explicit computer-use restriction from the written RFC was harmless because the vocational expert testified that the identified occupations did not involve substantive computer use.
3. The ALJ did not err by omitting absence or off-task limitations because the record did not establish work-preclusive absences or off-task time, no medical source identified such limitations, and the ALJ reasonably rejected the unsupported frequency reports on which the proposed limitations depended.
4. The vocational-expert hypothetical was proper because it incorporated the limitations the ALJ found credible and supported by the evidence; the ALJ was not required to include rejected absence, off-task, or computer-use limitations.

Questions Presented

1. Whether the ALJ built an accurate and logical bridge between the migraine evidence and the residual functional capacity assessment.
2. Whether the ALJ's failure to include an explicit computer-screen restriction in the written residual functional capacity was harmful error.
3. Whether the ALJ erred by omitting work-absence or off-task limitations attributable to migraines from the residual functional capacity and vocational-expert hypothetical.
4. Whether the vocational-expert hypothetical was proper because it included the limitations the ALJ found credible and supported by the record.

Disposition

affirmed