Michele D. v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of New York reviewed the denial of Michele D.’s application for Social Security disability insurance benefits. The court found that the Administrative Law Judge failed to clearly account for moderate social-interaction limitations in the residual functional capacity assessment, but held that the error was harmless because two identified jobs accommodated those limitations. The court denied the plaintiff’s motion, granted the Commissioner’s motion, affirmed the administrative decision, and dismissed the complaint.

Holdings

1. The ALJ erred by failing to clearly identify limitations concerning the claimant's ability to interact with coworkers, supervisors, and the public after finding a moderate limitation in interacting with others.
2. The RFC error was harmless because the jobs identified at step five accounted for moderate limitations in social interaction; accordingly, the Commissioner's denial of benefits was affirmed.

Questions Presented

1. Whether the ALJ erred by finding moderate limitations in interacting with others while failing to expressly include corresponding social-interaction limitations in the RFC.
2. Whether any RFC error was harmless because the jobs identified at step five accommodated moderate social limitations.

Disposition

affirmed