Morris W. Blair, Jr. v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Kentucky affirmed the Commissioner's denial of Morris W. Blair, Jr.'s applications for disability insurance benefits and supplemental security income. The court held that the Administrative Law Judge's decision, including the residual functional capacity assessment and treatment of mild mental limitations, was supported by substantial evidence. Plaintiff's motion for summary judgment was overruled, and the Commissioner's motion was sustained.

Holdings

1. The Commissioner's decision denying benefits was supported by substantial evidence and was affirmed.
2. The ALJ did not err by failing to include specific mental restrictions in the RFC because an ALJ is not required to discuss or incorporate every non-severe impairment into the RFC assessment, and the record independently supported the conclusion that Plaintiff's mild mental limitations did not prevent performance of his past relevant work.

Questions Presented

1. Whether substantial evidence supported the Commissioner's final decision finding Plaintiff not disabled.
2. Whether the ALJ erred by failing to include specific mental limitations in the residual functional capacity assessment after finding mild mental limitations at step two.

Disposition

affirmed