Hancock v. Astrue, No. 11-1001
Decided: January 5, 2012
Karen Hancock applied for Supplemental Security Income (SSI) for her alleged physical and mental disabilities. Her claim for benefits was denied pursuant to the inquiry given in 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4) that examine whether the claimant worked during the period of disability, had a severe impairment, had an impairment that that meets the requirements of an enumerated disability, could return to her past position after a period of impairment, or could perform any employment in the national economy. The Commissioner of the Social Security Administration found that Hancock did not have an impairment that met one listed in the regulations and that she was capable of performing other employment.
Hancock appealed the denial, contesting the Commissioner’s finding that she did not meet the three-pronged test for mental retardation. The Fourth Circuit, however, affirmed the decision of the Commissioner and Administrative Law Judge. The court held that given conflicting results of IQ tests, it was for the finder of fact, not the appellate court, to give weight to each piece of evidence. Moreover, Hancock’s past employment history supported a finding that she did not have deficiencies in adaptive functioning or that any mental disabilities did not manifest during developmental years. Having found that substantial evidence supported the finding that not all prongs of mental disability had been met, the court affirmed the decision below.
-C. Alexander Cable