Corrine B. v. Frank Bisignano, Commissioner of Social Security Administration

Summary

The United States District Court for the District of Rhode Island denied Corrine B.’s motion to reverse the denial of her claims for Supplemental Security Income and Social Security Disability Insurance and granted the Commissioner’s motion to affirm. The court held that substantial evidence supported the Administrative Law Judge’s residual functional capacity assessment, including the absence of a specific supervisor-interaction limitation and the assessment of the claimant’s ability to sustain a normal workday and workweek. Final judgment was ordered in favor of the Commissioner.

Holdings

1. The ALJ adequately supported the RFC's absence of a supervisor-interaction limitation because the state-agency psychological consultants found Corrine not significantly limited in accepting instructions and responding appropriately to criticism from supervisors, and Corrine reported getting along very well with authority figures.
2. The ALJ adequately accounted for Corrine's ability to sustain work over a normal workday and workweek by relying on the state-agency psychological consultants' findings that she could carry out simple tasks for two-hour periods over a normal workday and workweek and was not significantly limited in sustaining an ordinary routine without special supervision.

Questions Presented

1. Whether the ALJ adequately supported the RFC by omitting a specific limitation on Corrine's ability to interact with supervisors.
2. Whether the ALJ was required to make a separate express finding concerning Corrine's ability to complete a normal workday and workweek.

Disposition

affirmed