Connye L. v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Michigan reviews the Commissioner of Social Security’s denial of Conny[e] L.’s application for Supplemental Security Income. The court concludes that the Administrative Law Judge’s residual functional capacity assessment and finding that Plaintiff could perform a reduced range of light work were supported by substantial evidence, grants the Commissioner’s motion for summary judgment, and denies Plaintiff’s motion.

Holdings

1. A limitation to standing and walking for four hours in an eight-hour workday does not categorically preclude a reduced range of light work. The ALJ properly relied on vocational-expert testimony concerning jobs compatible with Plaintiff's specific RFC.
2. The ALJ was not required to apply a grid rule directing a finding of disability because Plaintiff's RFC fell between the sedentary and light ranges, and the ALJ appropriately consulted a vocational expert rather than mechanically applying a single exertional grid category.
3. Substantial evidence supported the ALJ's RFC assessment and conclusion that Plaintiff was not disabled under the Social Security Act.

Questions Presented

1. Whether the ALJ's RFC was internally inconsistent because it classified Plaintiff as capable of light work while limiting her to four hours of standing and walking in an eight-hour workday.
2. Whether the ALJ was required to classify Plaintiff as limited to sedentary work under the Medical-Vocational Guidelines because her exertional capacity fell between the sedentary and light ranges.
3. Whether the ALJ's evaluation of Plaintiff's neuropathy, fibromyalgia, obesity, degenerative disc disease, pain, balance problems, and concentration complaints was supported by substantial evidence.

Disposition

affirmed