Travis T. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Western District of Kentucky reviewed the Commissioner of Social Security’s denial of Travis T.’s application for disability insurance benefits. The court rejected challenges to the Administrative Law Judge’s residual functional capacity assessment, including alleged errors concerning adaptation limitations and the evaluation of a consultative examiner’s opinion. The court affirmed the Commissioner’s final decision as supported by substantial evidence and compliant with applicable regulations.

Holdings

1. An ALJ is not required to adopt a Paragraph B limitation from the step-three listings analysis as an identical limitation in the RFC assessment, because the two assessments serve different functions. The ALJ must nevertheless consider the effect of the limitation when formulating the RFC; here, the ALJ did so and reasonably determined that the claimant could adapt to changes in the workday routine.
2. The ALJ adequately evaluated Fishkoff's opinion and was not required to adopt her severe limitation concerning the ability to sustain attention on simple and repetitive tasks. The RFC limitation to understanding, remembering, and carrying out simple instructions, together with the prohibition on production-rate assembly-line work, reasonably accounted for the supported degree of concentration impairment.

Questions Presented

1. Whether the ALJ was required to incorporate the moderate Paragraph B limitation in adapting or managing oneself into the residual functional capacity assessment.
2. Whether the ALJ adequately evaluated Jennifer Fishkoff's consultative opinion and sufficiently accounted for evidence of impaired concentration in the residual functional capacity.

Disposition

affirmed