## Facts

- Robert Brindisi, a minor, applied for Supplemental Security Income (SSI) childhood disability benefits through his mother, alleging disability since birth.
- He had recurrent ear infections beginning before age two, leading to multiple surgeries to insert or replace ear tubes.
- The medical history included hearing impairment, speech and language delay, and behavioral problems associated with difficulty communicating.
- The record also noted attention-related symptoms that improved with medication, including an ability to sit and concentrate when medicated.
- Evidence showed he could perform age-appropriate self-care, including hygiene, and that speech therapy produced improvement.
- An Administrative Law Judge (ALJ) found a severe combination of impairments but concluded the impairments did not produce “marked and severe functional limitations” required for childhood disability.

## Issues

1. Whether the ALJ correctly applied the statutory and regulatory standards for childhood disability, including functional equivalence to the listings.
2. Whether substantial evidence supported the ALJ’s finding that Brindisi lacked “marked and severe functional limitations,” specifically because he had only one marked limitation and less-than-marked limitations in the other functional domains.

## Decision

- The district court affirmed the Commissioner’s final decision denying benefits.
- The court held the ALJ applied the correct childhood SSI framework, including domain-by-domain functional assessment.
- The court found substantial evidence supported the ALJ’s domain findings: marked limitation in speech/language; no motor limitation; less-than-marked limitations in social functioning, personal functioning, and concentration/persistence/pace.
- The court declined to reweigh conflicting evidence and concluded the ALJ sufficiently connected the evidence to the conclusions reached.

## Legal Principles

- A child is disabled for SSI purposes only if a medically determinable impairment causes “marked and severe functional limitations” expected to last at least 12 months (or result in death).
- Functional equivalence is assessed by rating limitations across specified domains; disability generally requires marked limitations in at least two domains or an extreme limitation in one.
- Judicial review under 42 U.S.C. § 405(g) is limited to whether the decision is supported by substantial evidence and free of legal error; courts do not substitute their judgment for the agency’s factfinding.
- An ALJ’s decision is upheld when it reasonably explains how record evidence supports the functional domain ratings, including consideration of improvement with treatment and demonstrated daily functioning.

## Conclusion

The court upheld the denial of childhood SSI benefits because substantial evidence supported the ALJ’s determination that, despite serious ear disease and related speech/hearing problems, Brindisi had only one marked functional limitation and did not meet the regulatory threshold for “marked and severe functional limitations.”


Brindisi v. Massanari, No. 00 C 8138, 2001 WL 1607485 (N.D. Ill. Dec. 17, 2001)