Narrative Opinion Summary
In the case of Rhonda Houston v. Shirley S. Chater, the Tenth Circuit Court reviewed a denial of supplemental security income (SSI) benefits for a minor, Delilah M. Houston, suffering from asthma. The Administrative Law Judge (ALJ) concluded that Delilah's asthma, while previously severe, did not meet or equal the criteria for listed impairments and was not of comparable severity to adult disabilities. The district court upheld this decision, finding substantial evidence to support the ALJ's determination. On appeal, Delilah's representative argued that her condition was equivalent to listed impairments, citing criteria requiring asthma attacks to necessitate medical intervention bi-monthly over a 12-month period. However, the evidence demonstrated effective management of the condition with medication and that it did not significantly impact her ability to function in age-appropriate activities; she attended school regularly, performed adequately, and interacted well with peers. The appellate court affirmed the district court's ruling, concluding that Delilah was not disabled under the relevant SSI standards. Consequently, the denial of benefits was upheld, and the court's decision was not considered binding precedent except under specific legal doctrines.
Legal Issues Addressed
Citation of Unpublished Opinionssubscribe to see similar legal issues
Application: Unpublished opinions may be cited if they hold persuasive value on a material issue, provided they are attached or furnished during proceedings.
Reasoning: Unpublished opinions may now be cited if they have persuasive value on a material issue, provided a copy is attached to the citing document or furnished to the court and parties during oral arguments, per the General Order of November 29, 1993.
Criteria for Asthma as a Disabling Conditionsubscribe to see similar legal issues
Application: Asthma must result in attacks requiring intensive medical intervention at least bi-monthly over a 12-month period to qualify as a disabling condition.
Reasoning: Ms. Houston's appeal references a particular version of the relevant disability criteria effective from April 1, 1994, which stipulates that asthma attacks, requiring medical intervention and occurring at least bi-monthly, must be documented over a minimum evaluation period of 12 months to consider disability.
Evaluation of Child Disability for Supplemental Security Incomesubscribe to see similar legal issues
Application: In determining the disability status of a child under SSI, the impairment must significantly hinder the child's development and ability to engage in age-appropriate activities.
Reasoning: For a child to be deemed disabled under the standards for comparable severity, the impairment must significantly hinder physical, mental, or emotional development and engagement in age-appropriate activities.
Substantial Evidence Standard in Administrative Reviewsubscribe to see similar legal issues
Application: The district court's review found substantial evidence supporting the ALJ's decision that the child's asthma did not meet the criteria for disability.
Reasoning: The district court, upon reviewing the case, found substantial evidence supporting the ALJ's decision.