Darryl Hammer v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of Ohio reviewed the Commissioner of Social Security’s denial of Darryl Hammer’s applications for Supplemental Security Income and Disability Insurance Benefits. The court rejected challenges concerning an alleged conflict between the residual functional capacity and vocational-expert testimony and the evaluation of State agency psychological opinions. The court affirmed the Commissioner’s nondisability determination and dismissed the complaint.

Holdings

1. The ALJ did not err in finding that Hammer could perform the identified jobs. The DOT's depth-perception requirements did not create an apparent conflict with the vocational expert's testimony because the expert testified that the jobs could be performed within the RFC, and Hammer failed to identify record evidence establishing an actual depth-perception limitation.
2. The ALJ reasonably evaluated the State agency psychological consultants' opinions and permissibly limited Hammer to occasional interaction with supervisors, coworkers, and the general public, while requiring superficial interaction only with coworkers and the public.

Questions Presented

1. Whether the ALJ's step-five finding was unsupported because the identified jobs required depth perception allegedly inconsistent with Hammer's limitation against work requiring binocular vision.
2. Whether the ALJ improperly evaluated the State agency psychological consultants' findings and thereby adopted a mental residual functional capacity unsupported by substantial evidence.

Disposition

affirmed