Butler v. Social Security Administration, Commissioner, 2:24-cv-00172

Plaintiff Sheianne Butler appealed the Social Security Administration’s denial of her claim for disability insurance benefits and supplemental security income, alleging ongoing disability beginning in 2006 (age 4).
Butler had a history of childhood sexual abuse, PTSD, learning problems, ADHD, and anxiety, with special education services and an individualized education program.
The ALJ determined her anxiety disorder and PTSD to be severe impairments but found no medical determination for ADHD, learning disorder, bipolar, or major depressive disorder after age 18.
Medical evidence included evaluations from psychologists and therapists, with variations in diagnoses and assessments of adaptive functioning and independence.
The ALJ ultimately found Butler did not meet the criteria for disability under the Social Security Act, as she retained a residual functional capacity for simple work with nonexertional limitations, and jobs existed in the national economy that she could perform.
Butler raised procedural and substantive challenges (steps two, three, and four of the five-step disability evaluation) on appeal to the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Step 2: Omission of ADHD & Learning Disorder	ALJ erred not finding these as medically determinable	Impairments considered later	No error; at least one severe impairment recognized; no prejudice
Step 3: Listing 12.05(B) (Intellectual Function)	ALJ erred finding only moderate adaptive deficits; working memory score meets criteria	Substantial evidence for moderate deficits	ALJ’s finding supported by substantial evidence; any IQ scoring error was harmless
Step 3: Use of Activities Requiring Assistance	ALJ relied on activities done with assistance	Plaintiff functionally independent	No error; substantial evidence plaintiff independent in daily living
Step 4: Residual Functional Capacity	ALJ underestimated impact of mental impairments	RFC assessment was proper	RFC finding supported; independence evidence relied upon

Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (standard for reviewing ALJ’s decision and five-step disability process)
Henry v. Comm’r of Soc. Sec., 802 F.3d 1264 (11th Cir. 2015) (substantial evidence standard)
Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (court must affirm if supported by substantial evidence even if evidence preponderates against it)
Cornelius v. Sullivan, 936 F.2d 1143 (11th Cir. 1991) (court must reverse if ALJ applies incorrect legal standards)
Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002) (burden of meeting Listing requirements)
Barron v. Sullivan, 924 F.2d 227 (11th Cir. 1991) (burden of proving a listed impairment)