Breslin v. Commissioner of Social Security

Martin Breslin (plaintiff) had some college education and intermittently worked in warehouses. In 1998, Breslin was fired for alcohol abuse and did not obtain alternate employment. In 2003, Breslin was admitted to the hospital for severe intoxication and diagnosed with congestive heart failure. Sometime later, 48-year-old Breslin applied to the Social Security Administration (SSA) for supplemental security income, claiming he was disabled. At a hearing before an administrative-law judge (ALJ), Breslin testified that he had stopped drinking in 2003. However, evidence showed that Breslin admitted daily alcohol use to a doctor in 2007. An assessment by a state-agency consultant concluded that Breslin was capable of light work with no more than two hours of standing or walking per day. Additionally, Breslin needed to avoid exposure to hazards like heights and machinery and could engage in only occasional balancing, stooping, kneeling, and stair climbing. The ALJ found the assessment’s limitations consistent with medical evidence but rejected Breslin’s self-reported additional limitations as unbelievable because of Breslin’s lack of medical evidence and inconsistent descriptions of his drinking. Based on Breslin’s residual functional capacity to do light work and on his age, education, and experience, the ALJ concluded that Breslin was not disabled for light work or sedentary work under the Social Security Medical-Vocational Guidelines, also known as the grid rules. When assessing Breslin’s occupational base, meaning the work he was capable of performing, the ALJ relied on Social Security Rulings holding that sedentary jobs did not require more than occasional balancing, stooping, kneeling, or stair climbing. Because the ALJ concluded that Breslin was not disabled, his application for supplemental security income was denied. Breslin filed suit to challenge the SSA decision. The district court affirmed. Breslin appealed.