Disability insurance benefits; Whether plaintiff was “disabled” under the Social Security Act; 42 USC §§ 416(i) & 423(d); 20 CFR § 404.1520(a)(4); Whether plaintiff retained the “residual functional capacity” to work as a cashier; Effect of her “mental impairments” on residual functional capacity; Whether the administrative law judge (ALJ) followed required procedure

The court held that there was substantial evidence to support the ALJ’s finding that plaintiff-Napier’s mental impairments were not severe but mild, and that the ALJ did not fail to account for those mental impairments in assessing her residual functional capacity. Using the “‘five-step sequential evaluation process’ for adjudicating claims of disability[,]” the ALJ concluded that Napier was not disabled at step four. The ALF determined that she “retained the ‘residual functional capacity’ to perform her past relevant work as a cashier.” Napier argued that the ALJ failed to explain how her mental impairments played into the residual functional capacity analysis. But the court noted that when asked what kept her from being able to work, she listed “physical symptoms and did not mention her depression or anxiety.” The court explained that this could have caused the ALJ to have “reasonably inferred that Napier did not consider herself to be severely affected by her mental impairments.” In addition, “the ALJ emphasized that Napier’s treatment history with respect to her anxiety and depression was quite limited” and noted the lack of any “history of inpatient or outpatient mental health treatment.” The ALJ summarized the findings of three different mental health professionals who opined that Napier did not suffer from severe mental impairments, and noted evidence that her symptoms could be controlled through medication. The ALJ also considered Napier’s testimony about her inability to perform her regular activities. The court held “that substantial other record evidence indicated that Napier’s mental impairments were not severe,” and that the ALJ did not err by including evidence about the activities she could perform in the analysis. The court also rejected her argument that the ALJ failed to follow the required procedures when assessing medical opinions, finding that these assertions were not supported by the record. The ALJ explicitly noted why it found two experts more convincing than a third. The court held that the record clearly showed “that the ALJ adequately accounted for Napier’s mental impairments in formulating her residual functional capacity[,]” and adequately considered her “limitations in the residual functional capacity analysis.” Thus, the court affirmed the district court’s judgment affirming the denial of Napier’s application for disability insurance benefits.