Brandy H. v. Commissioner of Social Security

Summary

The United States District Court for the Southern District of Ohio affirmed the Commissioner of Social Security’s denial of Brandy H.’s applications for Disability Insurance Benefits and Supplemental Security Income. The court held that substantial evidence supported the ALJ’s residual functional capacity assessment, including the decision not to include a cane-use limitation, and concluded that any reference to SSR 96-9p was harmless.

Holdings

1. The ALJ's reference to SSR 96-9p did not constitute reversible error. Even assuming the ruling was inapplicable to an RFC for light work, Plaintiff failed to show prejudice or deprivation of a substantial right.
2. Substantial evidence supported the ALJ's decision not to include a cane-use limitation in Plaintiff's RFC.
3. The ALJ did not improperly substitute lay judgment for medical judgment when evaluating Dr. Francillon's opinion.
4. The Commissioner's final decision denying DIB and SSI was supported by substantial evidence and was affirmed.

Questions Presented

1. Whether the ALJ committed reversible error by referring to Social Security Ruling 96-9p when evaluating whether Plaintiff medically required a cane despite assessing an RFC for light work.
2. Whether substantial evidence supported the ALJ's decision not to include a cane-use limitation in Plaintiff's residual functional capacity.
3. Whether the ALJ improperly substituted lay judgment for medical judgment when evaluating Dr. Francillon's consultative opinion.

Disposition

affirmed