The U.S. District Court for the Southern District of Illinois affirms a decision by the Commissioner of Social Security denying Supplemental Security Income (SSI) benefits to an applicant claiming a disability based on ADHD, depression, mood disorder, bipolar disorder, anxiety disorder, and mild intellectual disability. In Meshella, T. v Commissioner of Social Security (S.D. Ill., Case No. 3:21-CV-314-NJR, October 13, 2022).
Meshella T.’s mother applied for SSI benefits in 2014. The application was denied in January 2015 and again upon reconsideration in September 2015. Meshella T. requested and had a hearing before an administrative law judge in 2017. The ALJ issued a decision in 2018, finding Ms. T. was not disabled as a child or adult under separate provisions of the Social Security Act. The Appeals Counsel denied Ms. T.’s request for review, and she appealed to the federal court.
The District Court considers each element of Ms. T.’s appeal, but declines to reweigh the evidence, assess credibility, or substitute its judgment for that of the ALJ.
First, the court considers the evidentiary record the ALJ used to render his decision. The ALJ considered hearing testimony from many people, including Ms. T., her mother, and a vocational expert. In addition, the ALJ considered medical, school records, doctors, and Ms. T.’s special education teacher’s input. Although the ALJ found that Ms. T. met some of the statutory requirements to be considered disabled, he found the impairments did not meet the criteria of a listed impairment, either under child or adult standards. The ALJ found that Ms. T. could perform many jobs in the national economy.
Second, the court finds that the ALJ did not ignore evidence demonstrating Ms. T. had a more significant limitation in her ability to attend to tasks. The ALJ considered Ms. T.’s evidence on this issue, but concluded it was outweighed by other evidence.
Third, the court disagrees with Ms. T. that the ALJ ignored evidence regarding the degree of her impairments in interacting and relating with others.
Fourth, the court disagrees with Ms. T. that the ALJ did not give her preferred medical professionals too little weight in coming to his decision. The ALJ followed the directions outlined in applicable regulations about which medical professionals’ opinions and medical records should carry more weight than others.
Fifth, the court disagrees with Ms. T. that the ALJ did not consider all relevant evidence in the record in his residual functional capacity (RFC) assessment. Instead, the court finds that his RFC assessment is supported by substantial evidence, including testimony from Ms. T., her mother, and experts; input from Ms. T’s special needs teacher; exam notes; and medical diagnoses of ADHD. All of these support the ALJ’s conclusion that Ms. T. can perform simple, routine work that requires short, simple instructions and little independent judgment or decision-making.
