Byes v. Astrue, No. 11-3544 (8th Cir. 2012)
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Kevin Byes applied for disability insurance benefits and supplemental security income on July 30, 2007, claiming disability since November 1, 2005. The Commissioner of Social Security Administration (Commissioner) denied benefits. An administrative law judge (ALJ) upheld the Commissioner's decision, concluding that Byes was not disabled from November 1, 2005 through the date of the decision. The district court agreed with the ALJ's decision. The Eighth Circuit Court of Appeals affirmed, holding that substantial evidence supported the ALJ's finding of no severe mental impairment; and (2) the district court correctly concluded that the ALJ had applied the incorrect grid rule in order to determine Byes was not disabled but that the error was harmless.
Court Description: Civil case - Social Security. ALJ's finding that claimant did not suffer a severe mental impairment was supported by substantial evidence; ALJ's use of the wrong grid was harmless.
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