Autumn C. v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Maryland reviews the Social Security Administration’s denial of Autumn C.’s application for Supplemental Security Income benefits. The court holds that the Administrative Law Judge adequately supported the claimant’s residual functional capacity, including a limitation concerning specific production rates, and that the hypothetical question posed to the vocational expert was sufficiently explained. The Commissioner’s decision is affirmed.

Holdings

1. The ALJ adequately explained the limitation restricting Plaintiff to work not requiring a specific production rate because the decision identified relevant medical and other evidence and connected that evidence to the limitation.
2. The hypothetical question adequately described the production-rate limitation by giving examples such as assembly-line work and work requiring hourly quotas; the absence of a Dictionary of Occupational Titles definition did not require remand.

Questions Presented

1. Whether the ALJ adequately explained the residual functional capacity limitation restricting Plaintiff from work requiring a specific production rate.
2. Whether the ALJ's hypothetical question to the vocational expert adequately defined the term specific production rate and accurately reflected Plaintiff's supported limitations.

Disposition

affirmed