Molly C., as Estate Administrator for Nicholas C. (deceased), v. Frank Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the District of Rhode Island reviews a Social Security Administration decision denying Nicholas C.'s application for Disability Insurance Benefits. The court rejects arguments that the administrative law judge failed to account for treatment noncompliance allegedly caused by mental impairments and failed to address absenteeism or off-task limitations. The court denies the plaintiff's motion to reverse, grants the Commissioner's motion to affirm, and directs entry of judgment for the defendant.

Holdings

1. The ALJ did not err in considering the limited specialty mental-health treatment and treatment history when evaluating the intensity and persistence of the claimant's symptoms. The record did not show a failure to follow prescribed treatment caused by mental impairment, and substantial evidence independently supported the ALJ's assessment.
2. The ALJ did not err in finding that the claimant could sustain a normal work schedule. The non-examining psychologists expressly found that he could sustain a normal work routine despite moderate limitations in specified functional areas.
3. Moderate mental limitations are not per se preclusive of the ability to work.

Questions Presented

1. Whether the ALJ improperly relied on limited mental-health treatment without considering whether Nicholas C.'s mental impairments deprived him of the rationality to decide whether to continue treatment.
2. Whether the ALJ erred by finding that Nicholas C. could sustain a normal workday and workweek despite moderate limitations identified by non-examining psychologists.
3. Whether the ALJ was required to conduct a separate absenteeism or off-task-time analysis.

Disposition

affirmed