Summary
The United States District Court for the Eastern District of Kentucky reviews the denial of Ralph Blackburn’s application for Social Security disability insurance benefits. The court holds that the Administrative Law Judge’s residual functional capacity assessment, including limitations addressing Blackburn’s mental impairments and headaches, was supported by substantial evidence and denies Blackburn’s request for remand.
Holdings
- The RFC was supported by substantial evidence and did not commit reversible error by limiting Blackburn to simple tasks, barring production-rate assembly-line work, and permitting adaptation to changes in a simple workday routine.
- The RFC adequately accounted for Blackburn's moderate limitation in interacting with others by restricting him to occasional social interaction consistent with giving and taking instructions.
- Blackburn failed to show that his migraines medically equaled Listing 11.02B or 11.02D, and the ALJ's step-three finding was supported by substantial evidence.
- The ALJ did not err by declining to include additional headache-related limitations because Blackburn cited no medical evidence connecting his headaches to specific work-related functional restrictions.
- The ALJ adequately explained the adverse evaluation of Blackburn's subjective complaints, and that determination was supported by substantial evidence.
Questions Presented
- Whether the RFC adequately accommodated Blackburn's moderate limitations in concentrating, persisting, or maintaining pace.
- Whether the RFC adequately accommodated Blackburn's moderate limitation in interacting with others.
- Whether Blackburn's migraine headaches medically equaled Listing 11.02 under Social Security Ruling 19-4p.
- Whether the ALJ erred by failing to include additional headache-related functional restrictions in the RFC.
- Whether the ALJ adequately explained the evaluation of Blackburn's subjective complaints.
Disposition
affirmed
Cases Cited (37)
- Jones v. Comm'r of Soc. Sec., 336 F.3d 469, 474, 476 (6th Cir. 2003)(followed)
- Cruse v. Comm'r of Soc. Sec., 502 F.3d 532, 539 (6th Cir. 2007)(followed)
- Rogers v. Comm'r of Soc. Sec., 486 F.3d 234, 241, 247, 249 (6th Cir. 2007)(followed)
- Cutlip v. Sec'y of Health & Human Servs., 25 F.3d 284, 286 (6th Cir. 1994)(followed)
- Mullen v. Bowen, 800 F.2d 535, 545 (6th Cir. 1986) (en banc)(followed)
- Kirk v. Sec'y of Health & Human Servs., 667 F.2d 524, 535, 538 (6th Cir. 1981)(followed)
- Bradley v. Sec'y of Health & Human Servs., 862 F.2d 1224, 1228 (6th Cir. 1988)(followed)
- Her v. Comm'r of Soc. Sec., 203 F.3d 388, 389-90 (6th Cir. 1999)(followed)
- Casey v. Sec'y of Health & Human Servs., 987 F.2d 1230, 1233 (6th Cir. 1993)(followed)
- Kinsella v. Schweiker, 708 F.2d 1058, 1059 (6th Cir. 1983)(followed)
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