Summary
The United States District Court for the Western District of Arkansas reviewed the denial of a minor’s application for supplemental security income benefits. The court held that substantial evidence supported the administrative law judge’s determination that the claimant’s impairments did not meet, medically equal, or functionally equal a listed impairment. The court affirmed the Commissioner’s decision denying benefits.
Topics
Practice areas
Questions Presented
- Whether the ALJ erred by finding that M.B.'s impairments did not meet or medically equal a listed impairment, including Listings 101.17, 101.18, 101.21, and 110.08.
- Whether the ALJ properly evaluated the six domains of functioning and correctly found that M.B.'s impairments were not functionally equivalent to a listed impairment.
- Whether substantial evidence supported the Commissioner's denial of childhood supplemental security income benefits.
Holdings
- The ALJ did not err in finding that M.B.'s impairments did not meet or medically equal a listed impairment. The record did not establish the specified assistive-device or upper-extremity requirements of Listing 101.18, the required documented medical need under Listing 101.17, continuing surgical management under Listing 101.21, or a disorder covered by Listing 110.08.
- The ALJ properly determined that M.B.'s impairments were not functionally equivalent to a listed impairment because the evidence did not show marked limitations in two domains or an extreme limitation in one domain.
- The Commissioner's denial of benefits was supported by substantial evidence and was affirmed.
Key quotations
“As long as there is substantial evidence in the record that supports the Commissioner’s decision, the Court may not reverse it simply because substantial evidence exists in the record that would have supported a contrary outcome or because the Court would have decided the case differently.” (Applicable Law)
“If, after reviewing the record, it is possible to draw two inconsistent positions from the evidence and one of those positions represents the findings of the ALJ, the decision of the ALJ must be affirmed.” (Applicable Law)
Factual background
M.B. applied for childhood supplemental security income, alleging disability beginning February 20, 2009. The ALJ found severe impairments including bilateral club feet status post-surgery, acquired equinus deformity of both feet, bilateral knee arthrogryposis, leg-length discrepancy, corns, and callosities. The ALJ found no limitation in four functional domains, a marked limitation in moving about and manipulating objects, and a less-than-marked limitation in health and physical well-being. The district court concluded that the medical records, teacher assessments, testimony, and state-agency medical-consultant opinions substantially supported the ALJ's findings.
Procedural history
M.B.'s mother filed a childhood disability application on January 31, 2022. The Social Security Administration denied the application initially and on reconsideration; after a hearing on April 8, 2024, the ALJ issued an unfavorable decision. The Appeals Council denied review on August 27, 2025, and Plaintiff sought review in the district court. The parties consented to magistrate-judge jurisdiction, and the court affirmed the ALJ's decision.