Rachel Geneva Ernest v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania reviewed the Commissioner of Social Security’s denial of Rachel Geneva Ernest’s disability and supplemental security income benefits. The court held that substantial evidence supported the ALJ’s consideration of Ernest’s obesity and claimed need for a cane, and affirmed the Commissioner’s decision.

Holdings

1. The ALJ adequately considered Ernest's obesity and sufficiently explained its effect, if any, on her functional limitations; substantial evidence supported the resulting residual functional capacity.
2. The ALJ was not required to include cane use in the residual functional capacity because Ernest did not establish that a cane was medically required, and the ALJ in any event considered assistive-device use in a vocational-expert hypothetical. The alleged error therefore did not warrant remand.

Questions Presented

1. Whether substantial evidence supported the ALJ's consideration of Ernest's obesity in determining her residual functional capacity.
2. Whether the ALJ erred by failing to include Ernest's alleged cane use in the residual functional capacity assessment and vocational-expert hypothetical.

Disposition

affirmed