Randi L. Organ v. Frank Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the Eastern District of Oklahoma reviewed Randi L. Organ’s challenge to the denial of supplemental security income benefits under 42 U.S.C. § 405(g). The court held that the Administrative Law Judge applied the correct legal standards and that the residual functional capacity assessment and step-five vocational findings were supported by substantial evidence. The court affirmed the Commissioner of Social Security’s decision.

Holdings

1. The ALJ's residual functional capacity assessment complied with Social Security Ruling 96-8p and was supported by substantial evidence because the ALJ discussed the medical evidence, objective findings, testimony, and reasons for the limitations imposed.
2. The ALJ was not required to include additional RFC limitations for Organ's anxiety and depression because Organ identified no record evidence, apart from her own assertions, establishing functional limitations attributable to those impairments.
3. The ALJ properly relied on the vocational expert's testimony that Organ could perform the identified jobs despite the restriction against overhead reaching with the left upper extremity.

Questions Presented

1. Whether the ALJ adequately explained and supported Organ's residual functional capacity assessment under Social Security Ruling 96-8p.
2. Whether the ALJ was required to include additional limitations based on Organ's nonsevere anxiety and depression.
3. Whether the ALJ met the step-five burden by relying on vocational-expert testimony concerning jobs compatible with the limitation against overhead reaching with the left upper extremity.

Disposition

affirmed