Background
The plaintiff appealed the district court’s judgment affirming the Commissioner of the Social Security Administration’s denial of his application for supplemental security income disability benefits under Title XVI of the Social Security Act. The administrative law judge found the plaintiff could perform unskilled jobs despite a need for a five-minute break every hour due to monocular eye fatigue.
The court’s reasoning
The court reviewed the administrative law judge’s decision de novo, noting that the decision is disturbed only if not supported by substantial evidence or based on legal error. The court rejected the plaintiff’s argument that the Program Operations Manual System was binding, stating it is not binding authority. The court found the vocational expert’s testimony sufficient to support the finding that the plaintiff could perform identified jobs. Furthermore, the court held that the need for hourly five-minute breaks due to physical limitations does not constitute a reasonable accommodation under the Americans with Disabilities Act because such breaks are not inconsistent with how the jobs are generally performed.
What it means going forward
This decision clarifies that routine breaks for physical limitations do not require reasonable accommodations under the ADA in the context of Social Security disability determinations, reinforcing the reliance on vocational expert testimony for step-five findings.