Rosa R. v. Frank Bisignano O'Malley, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Washington affirmed the Social Security Administration ALJ’s denial of disability and supplemental security income benefits to Plaintiff Rosa R. The court rejected Plaintiff’s arguments that the ALJ improperly classified her education as marginal rather than illiterate and improperly evaluated her subjective complaints concerning headaches. The court concluded that any alleged errors were not consequential and did not warrant remand.

Holdings

1. The ALJ did not commit consequential error by finding that Plaintiff had a marginal education rather than illiteracy. The record substantially supported the finding that Plaintiff could read and write a simple message in Spanish, and remand was unwarranted.
2. The ALJ adequately evaluated Plaintiff’s subjective complaints and supported the evaluation with substantial evidence. The ALJ appropriately considered physical examinations, medical workups, symptom improvement with medication, and the absence of significant subsequent headache complaints.

Questions Presented

1. Whether the ALJ erred by finding that Plaintiff had a marginal education rather than illiteracy and by omitting an illiteracy limitation from the residual functional capacity.
2. Whether the ALJ improperly evaluated Plaintiff’s subjective complaints concerning migraine headaches.

Disposition

affirmed