Narrative Opinion Summary
In this case, the appellant, on behalf of her daughter, contested the denial of supplemental security income benefits by the Social Security Administration. The appellant's daughter, diagnosed with mild mental retardation and attending regular classes with modifications, was assessed under the SSA's three-step test for childhood disability. The Administrative Law Judge (ALJ) concluded that while the impairment was severe, it did not meet the criteria for medical or functional equivalency under the relevant listings, particularly 112.05E, based on substantial evidence. The appellant argued that the daughter's IQ and noted difficulties should qualify her for benefits, but the evidence, including school reports and teacher assessments, indicated her functioning was adequate. The district court upheld the ALJ's decision, emphasizing the lack of extreme limitations in acquiring and using information. On appeal, the court affirmed this decision, noting that the substantial evidence standard was met, and the appellant's new arguments could not be considered. Ultimately, the denial of benefits was affirmed, as the evidence did not support significant limitations under the relevant legal framework.
Legal Issues Addressed
Evidentiary Requirements for 'Extreme' Limitationssubscribe to see similar legal issues
Application: Breanna's activities and academic performance were insufficient to establish an 'extreme' limitation, as her functional ability indicated otherwise.
Reasoning: Breanna's daily activities do not support a claim of low IQ, as her good academic performance indicates she can acquire and use new information effectively with proper support.
Functional Equivalency under 20 C.F.R. 416.926asubscribe to see similar legal issues
Application: The court upheld the ALJ's finding that Breanna did not have extreme limitations in acquiring and using information, as her performance did not substantiate such a claim.
Reasoning: Tammy Moore contended that Breanna's impairments were functionally equivalent to listed impairments under 20 C.F.R. 416.926a, asserting an 'extreme' limitation in her ability to 'acquire and use information.'
Medical Equivalency under Listing 112.05Esubscribe to see similar legal issues
Application: The ALJ determined that Breanna's impairments did not meet the medical equivalency criteria for listed impairments, as she did not exhibit marked difficulties in concentration, persistence, or pace.
Reasoning: Moore argues that substantial evidence does not support the Commissioner's conclusion that Breanna's impairments were not medically equivalent to listing 112.05E, which requires a valid IQ score between 60 and 70 and specific difficulties.
Social Security Administration's Three-Step Test for Childhood Disabilitysubscribe to see similar legal issues
Application: The court applied the three-step test to determine if Breanna Moore's impairments were severe and met medical or functional equivalency to listed impairments.
Reasoning: The Social Security Administration follows a three-step test for determining childhood disability: (1) assessing if the child engages in substantial gainful activity; (2) determining if the child has a severe impairment; and (3) evaluating if the impairment is medically or functionally equivalent to listed impairments.
Substantial Evidence Standard in Social Security Appealssubscribe to see similar legal issues
Application: The court found that substantial evidence supported the ALJ's decision, considering both supporting and detracting evidence, and affirmed the denial of benefits.
Reasoning: The court reviews the district court's affirmation of the denial of social security benefits de novo, affirming if the Commissioner's findings are supported by substantial evidence.