Talavera v. Commissioner of Social Security, No. 11-4209 (2d Cir. 2012)Annotate this Case
Plaintiff appealed from the judgment of the district court affirming the Social Security Administration's (SSA) denial of her application for Supplemental Security Income disability benefits on the basis of her alleged intellectual disability. The court held that evidence of a petitioner's cognitive limitations as an adult established a rebuttable presumption that those limitations arose before petitioner turned 22, as was required by SSA regulations. The court further held that a petitioner must make separate showings of deficits in cognitive and adaptive functioning in order to be considered intellectually disabled under SSA regulations. Because the agency's finding that petitioner did not suffer from qualifying deficits in adaptive functioning was supported by substantial evidence, the court affirmed the judgment.