James D. Dieter v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of Ohio overruled James D. Dieter’s objection to a magistrate judge’s Report and Recommendation and adopted the recommendation affirming the Commissioner of Social Security’s denial of benefits. The court held that the administrative law judge adequately defined and applied the limitation to “superficial” workplace interactions and was not required to adopt a definition from an unrelated Appeals Council decision.

Holdings

1. The ALJ was not required to address the substance of a definition of superficial interaction contained in a nonbinding Appeals Council order from an unrelated case.
2. The Commissioner's decision was affirmed because Plaintiff failed to establish reversible error in the ALJ's treatment of the superficial-interaction limitation.

Questions Presented

1. Whether the ALJ was required to address and apply a definition of superficial workplace interaction stated in an Appeals Council order issued in an unrelated Social Security case.
2. Whether the ALJ's definition of superficial interactions and resulting RFC were supported by substantial evidence and complied with applicable legal standards.

Disposition

affirmed