Vicki A. v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois affirmed the Commissioner of Social Security’s denial of Vicki A.’s applications for disability insurance benefits and supplemental security income. The court rejected arguments concerning the retroactive application of Social Security Ruling 24-2p’s five-year past-relevant-work period, the adequacy of the residual functional capacity assessment, and the evaluation of subjective symptoms.

Holdings

1. The court must apply the rules in effect when the ALJ issued the decision and therefore would not apply Social Security Ruling 24-2p and the corresponding five-year timeframe retroactively.
2. The ALJ adequately accounted for Plaintiff's moderate concentration, persistence, or pace limitations by limiting her to understanding, remembering, and carrying out simple, routine instructions and making simple work-related decisions.
3. The ALJ's evaluation of Plaintiff's subjective symptoms was adequately supported and was not patently wrong.

Questions Presented

1. Whether the court should apply the Social Security Administration's post-decision five-year definition of past relevant work retroactively to Plaintiff's claims.
2. Whether the ALJ adequately accounted for Plaintiff's moderate limitations in concentration, persistence, or pace in the residual functional capacity assessment.
3. Whether the ALJ improperly evaluated Plaintiff's subjective symptoms.

Disposition

affirmed