Kristina M. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of Washington affirmed the Commissioner of Social Security’s denial of the plaintiff’s applications for SSI, DIB, and Childhood Disability Benefits. The court held that the ALJ did not commit harmful error in assessing the plaintiff’s residual functional capacity or in declining to include additional limitations related to migraine frequency and workplace attendance, and dismissed the case with prejudice.

Holdings

1. The ALJ did not err by declining to include additional migraine-related limitations in the RFC because Plaintiff did not identify record-supported limitations independent of subjective symptom reports that the ALJ had properly discounted.
2. The court declined to consider the argument because it was raised for the first time in Plaintiff's reply brief and, alternatively, held that Plaintiff identified no persuasive authority requiring the ALJ to make a separate finding regarding migraine frequency.
3. The Commissioner's final decision denying benefits was affirmed because Plaintiff failed to demonstrate harmful legal error or a lack of substantial evidence.

Questions Presented

1. Whether the ALJ erred in assessing Plaintiff's residual functional capacity by failing to include additional limitations allegedly caused by migraine headaches, including limitations on attendance.
2. Whether the Commissioner's final decision was supported by substantial evidence and free of harmful legal error.

Disposition

affirmed