Katherine Johnson v. Carolyn Colvin, 788 F.3d 870

Katherine Johnson applied for SSI in 2010; ALJ denied benefits and the district court affirmed. Appeal challenges ALJ’s conclusion that Johnson does not meet Listing 12.05C for intellectual disability.
Medical testing: Dr. Nicholas (July 2010 WAIS‑IV) reported FSIQ 67 and diagnosed "mild mental retardation"; he also noted intact concentration and coherent thought processes and recommended mechanical-type work. Dr. Spellmann (May 2010) found Johnson not within the mentally retarded range and that mental impairments did not significantly interfere with day‑to‑day adaptive functioning.
Functional history: Johnson completed ninth grade (some special education), can read and write to a limited degree, count change, use public transportation, perform household tasks, cook meals, and raise her youngest child.
ALJ found severe impairments including borderline intellectual functioning but concluded Johnson did not have deficits in adaptive functioning manifest before age 22 sufficient to meet Listing 12.05C; ALJ assessed residual functional capacity for light work with restrictions and relied on vocational expert testimony to deny benefits.
Appeals Council denied review; this court reviews the ALJ’s decision for substantial evidence and affirmed, holding the record supports the ALJ’s finding that Johnson lacks the adaptive deficits required by Listing 12.05C.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Johnson meets Listing 12.05C (intellectual disability)	Johnson argues she has significantly subaverage IQ (FSIQ 67) and adaptive deficits since childhood to satisfy the listing	Commissioner argues record evidence (daily activities, examiners’ observations) shows no deficits in adaptive functioning manifest before age 22	Court held Johnson did not demonstrate the requisite adaptive‑functioning deficits; ALJ decision affirmed

Hill v. Colvin, 753 F.3d 798 (8th Cir. 2014) (describing five‑step disability evaluation)
Maresh v. Barnhart, 438 F.3d 897 (8th Cir. 2006) (standard of review for social security denials)
Howard v. Massanari, 255 F.3d 577 (8th Cir. 2001) (definition of substantial evidence)
Nguyen v. Chater, 75 F.3d 429 (8th Cir. 1996) (courts must affirm if reasonable evidence supports either of two inconsistent positions)
Cheatum v. Astrue, [citation="388 F. App'x 574"] (8th Cir. 2010) (daily activities inconsistent with Listing 12.05C adaptive deficits)
Clark v. Apfel, 141 F.3d 1253 (8th Cir. 1998) (ability to read/write, care for household supports non‑listing finding)
Johnson v. Barnhart, 390 F.3d 1067 (8th Cir. 2004) (ALJ decision not reversible simply because evidence could support opposite conclusion)