KANSAS CITY – The U.S. District Court for the Western District of Missouri upheld Acting Commissioner of Social Security Nancy A. Berryhill’s decision to deny Social Security disability benefits to a claimant that an administrative law judge (ALJ) deemed capable of performing some job duties, according to an order entered on May 23.
The district court said in its order that the ALJ ruled that plaintiff Laurie Jean Johnson “had severe impairments of degenerative disk disease of the cervical spine and obesity, but she retained the residual functional capacity (RFC) to perform work as a retail price marker, small parts assembler and collator operator.”
Johnson applied for Social Security disability benefits on May 12, 2014, according to the order. In her application, the court said Johnson claimed that she became disabled on July 22, 2011. Following an appeal of the initial denial of benefits, the ALJ ruled on Jan. 26, 2016, that Johnson “was not disabled.”
According to the district court order, Johnson alleged in her lawsuit that the ALJ did not take into account Johnson’s obesity-related work restrictions, “mental impairment” and her ability to work on a “function-by-function basis” and that the ALJ made his decision based on his “own medical opinion.”
The court said Johnson alleged that the ALJ should have instead found that she “cannot perform any of the jobs identified by the vocational expert.”
In the order, U.S. District Court Chief Judge Greg Kays said the vocational expert’s testimony “is substantial evidence,” even if Johnson did not agree with his findings.
In response to the plaintiff’s argument that the ALJ failed to assess her ability to work on a function-by-function basis, the district court said “the ALJ did not simply limit plaintiff to ‘light work,’ but instead included various additional and specific non-exertional, postural, and environmental limitations as part of the (ruling).”
Kays also said the ALJ did adequately consider limitations imposed by Johnson’s obesity on her ability to work, even though the plaintiff never cited obesity in her application for benefits.
Finally, the court ruled that Johnson’s “mental symptoms did not cause more than a minimal limitation in her ability to do basic work activities,” so no mental impairment restrictions were needed.