Brindisi v. Massanari

Robert Brindisi’s mother (plaintiff) filed an application for Social Security income on his behalf, claiming that Brindisi had been disabled since he was born in 1992, due to persistent ear infections that caused him to have a serious hearing impairment and speech issues. Brindisi’s application was initially denied. Following a hearing, the denial was affirmed based on an administrative-law judge’s (ALJ) conclusion that Brindisi suffered from a severe combination of impairments. However, the limitations caused by the impairments were marked in the area of speech and language, but there were no limitations in the area of motor development and less-than-marked limitations in the areas of social and personal development and in the area of concentration, persistence, and pace. The record showed that Brindisi could care for his own hygiene, and although he had severe speech delays and social anxiety that caused him to act out when unable to express himself, Brindisi’s speech improved with therapy, and he was able to sit and concentrate when he medicated for his attention deficit disorder. Accordingly, Brindisi’s impairments did not result in marked and severe functional limitations, and he was found not disabled. The appeals council denied review of the ALJ’s decision, and the decision became the final decision of the Commissioner of the Social Security Administration, Larry Massanari (defendant). Brindisi requested judicial review of the commissioner’s denial in a United States district court.