Anne A. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois reviewed the Commissioner of Social Security’s denial of Anne A.’s claim for Disability Insurance Benefits. The court held that the ALJ adequately accounted for Plaintiff’s moderate limitation in concentration, persistence, and pace by restricting her to simple, routine tasks, denied the request for reversal, and affirmed the Commissioner’s decision.

Holdings

1. The restriction to simple routine work adequately accounted for Plaintiff's moderate limitation in concentration, persistence, and pace, including her ability to sustain focus throughout the workday.
2. The ALJ was not required to discuss vocational-expert testimony concerning tolerated off-task time because the ALJ did not find that Plaintiff would experience time off task.
3. The Commissioner's decision denying Disability Insurance Benefits was supported by substantial evidence and was affirmed.

Questions Presented

1. Whether the ALJ's RFC adequately accounted for Plaintiff's moderate limitation in concentration, persistence, and pace by restricting her to simple routine tasks and frequent interaction with others.
2. Whether the ALJ was required to address vocational-expert testimony concerning the amount of time off task an employer would tolerate when the ALJ did not find that Plaintiff would be off task.
3. Whether the ALJ's decision was supported by substantial evidence and applied the correct legal standards.

Disposition

affirmed