Bradley N.A. v. Bisignano

Summary

The court denied Bradley N.A.’s request for remand in an action seeking review of the Commissioner of Social Security’s denial of disability insurance benefits. The court held that the Administrative Law Judge applied the correct disability-evaluation process, supported the residual functional capacity determination with substantial evidence, and adequately explained the finding that Bradley would be off task no more than five percent of the workday.

Holdings

1. The ALJ adequately explained the RFC finding that Bradley could understand, remember, and carry out instructions for at least 95 percent of an eight-hour workday by connecting the finding to medical opinions, treatment history, mental-status examinations, and Bradley's daily activities.
2. The Fourth Circuit's law does not categorically prohibit an ALJ from expressing a qualitative concentration, persistence, or pace limitation as a numerical percentage of the workday, and the ALJ's five-percent off-task finding was adequately supported here.
3. The Commissioner's decision was legally correct and supported by substantial evidence.

Questions Presented

1. Whether the ALJ adequately explained the residual functional capacity finding that Bradley could understand, remember, and carry out instructions for 95 to 100 percent of an eight-hour workday.
2. Whether the ALJ's numerical finding that Bradley would be off task for no more than five percent of the workday lacked a sufficient evidentiary and logical basis.
3. Whether the ALJ's evaluation of Bradley's mental and physical limitations was supported by substantial evidence.

Disposition

affirmed