Background

• Latasha Bonet, on behalf of her minor son TB, seeks SSI benefits for alleged disability due to attention deficit disorder.
• An Administrative Law Judge denied TB’s disability benefits, and Bonet’s challenge was denied by the District Court, which granted judgment on the pleadings for the Commissioner.
• The Second Circuit reviews de novo a district court’s grant of judgment on the pleadings and conducts plenary review of the administrative record for SSI determinations.
• The court assesses whether the SSA’s conclusions are supported by substantial evidence and based on correct legal standards.
• Bonet argues the ALJ failed to account for TB’s structured school setting in evaluating disability; the district court and ALJ’s reasoning are, however, found to be supported by substantial evidence.
• The court affirms the District Court’s judgment, holding the ALJ’s decision was supported by substantial evidence and correct legal standards.

Issues

Key Cases Cited

• Jasinski v. Barnhart, 341 F.3d 182 (2d Cir. 2003) (de novo review of district court grant of judgment on the pleadings)
• Lamay v. Comm’r of Soc. Sec., 562 F.3d 503 (2d Cir. 2009) (plenary review of the administrative record in SSI denial)
• Talavera v. Astrue, 697 F.3d 145 (2d Cir. 2012) (substantial evidence standard; focus on SSA conclusions)
• Selian v. Astrue, 708 F.3d 409 (2d Cir. 2013) (if substantial evidence supports agency’s determination, uphold)
• Brault v. Social Sec. Admin., Comm’r, 683 F.3d 443 (2d Cir. 2012) (ALJ not required to state every reason or discuss every piece of evidence)
• Rutherford v. Schweiker, 685 F.2d 60 (2d Cir. 1982) (factual issues need not align with preponderance; substantial evidence required)