Stout v. Commissioner

Gordon Stout (plaintiff) applied for Social Security disability benefits and supplemental security income, claiming that he was disabled due to back and mental impairments. Stout’s applications were denied following a hearing before an administrative-law judge (ALJ), who concluded that Stout was not disabled because he had the residual functional capacity (RFC) to perform his former work as a vine pruner. In reaching his conclusion, the ALJ rejected the testimonies of Stout’s sister and brother-in-law, who both testified consistently with the medical evidence that Stout lacked the mental capacity to deal with the demands of work. Stout’s sister testified that Stout had a history of mental impairments and self-destructive behavior, and Stout’s brother-in-law, who was Stout’s former boss and coworker for 10 years, testified that Stout was unable to perform simple tasks without constant supervision and accommodations. Although a vocational expert testified that a need for constant supervision would be unacceptable in competitive employment, the ALJ silently ignored the lay testimony of both witnesses in reaching his conclusion that Stout had the RFC to perform a wide range of light unskilled work including his previous work. The ALJ’s decision became the final decision of the Commissioner of the Social Security Administration (defendant). Stout sought judicial review of the ALJ’s decision, claiming that the ALJ’s rejection of his sister and brother-in-law’s testimony without comment was erroneous. The commissioner conceded error but argued that the error was harmless. A United States district court found in favor of the commissioner after finding that the error was harmless because Stout had a lengthy work history, including that of unsupervised work as a roofer after the work with his brother-in-law concluded. Stout appealed.