Tammy M. Rooney v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The United States District Court for the Western District of Pennsylvania affirmed the Commissioner of Social Security’s denial of Tammy M. Rooney’s application for Disability Insurance Benefits. The court held that the residual functional capacity adequately accounted for Rooney’s moderate limitations in concentration, persistence, and pace, that the ALJ was not required to include every limitation from the state agency psychologists’ opinions, and that no apparent conflict existed between the RFC limitation to simple, routine tasks and the identified occupations’ DOT reasoning levels. Rooney’s motion for summary judgment was denied.

Holdings

1. The ALJ adequately explained why a limitation to simple, routine tasks accommodated Rooney's moderate limitation in concentration, persistence, and pace, and the RFC was supported by substantial evidence.
2. The ALJ did not commit legal error by omitting the one- to two-step-task limitation because the ALJ was only generally persuaded by the state-agency opinions and was not required to adopt every limitation in those opinions or separately explain every omission.
3. The RFC limitation to simple, routine tasks did not create an inherent or per se conflict with the jobs identified by the vocational expert, which required DOT reasoning levels 2 or 3.

Questions Presented

1. Whether the ALJ adequately explained how an RFC limitation to simple, routine tasks accommodated Rooney's moderate limitation in concentration, persistence, and pace.
2. Whether the ALJ committed legal error by omitting a one- to two-step-task limitation recommended by state-agency psychologists from the RFC.
3. Whether the RFC limitation to simple, routine tasks conflicted with the vocational expert's identification of jobs requiring DOT reasoning levels 2 and 3.

Disposition

affirmed