Ana Cancel-Muñiz o/b/o A.Y.L.C. v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Puerto Rico affirmed the Commissioner of Social Security’s denial of supplemental security income benefits for a child claimant. The court held that the administrative law judge’s determination that the claimant’s impairments did not meet, medically equal, or functionally equal a listed impairment was supported by substantial evidence. The court rejected challenges concerning the domains of acquiring and using information, interacting and relating with others, and health and physical well-being.

Holdings

1. The court must uphold the Commissioner's decision when the ALJ applied the correct legal standards and the decision is supported by substantial evidence; the reviewing court may not reweigh the evidence.
2. A child is functionally equal to a listed impairment only if the impairment results in marked limitations in two domains of functioning or an extreme limitation in one domain.
3. Any alleged error in the ALJ's evaluation of the acquiring-and-using-information domain was harmless because the claimant did not show marked limitations in another domain or an extreme limitation in any domain.
4. Substantial evidence supported the ALJ's finding that the claimant had less than a marked limitation in interacting and relating with others.
5. Substantial evidence supported the ALJ's finding that the claimant had less than a marked limitation in health and physical well-being; frequent episodes do not automatically require a finding of marked limitation under 20 C.F.R. § 416.926a(e)(2)(iv).
6. Any alleged error concerning the interacting-and-relating-with-others or health-and-physical-well-being domains was harmless because the claimant could not demonstrate marked limitations in another domain.

Questions Presented

1. Whether the ALJ's finding that the claimant had less than a marked limitation in acquiring and using information was supported by substantial evidence and adequately explained.
2. Whether the ALJ's finding that the claimant had less than a marked limitation in interacting and relating with others was supported by substantial evidence.
3. Whether the ALJ's finding that the claimant had less than a marked limitation in health and physical well-being was supported by substantial evidence.
4. Whether any alleged errors in evaluating the functional domains were harmless because the claimant did not establish marked limitations in another domain.

Disposition

affirmed