Sanchez v. Social Security

Background

Armani Sanchez sought judicial review of the Commissioner of Social Security’s denial of his application for child’s insurance benefits under Title II of the Social Security Act. He alleged disability from mental impairments, including bipolar disorder and learning delays. The administrative law judge found that Sanchez had bipolar disorder and a learning disability before age 22, but concluded that his impairments did not meet or equal a listed impairment and that he could perform work existing in significant numbers in the national economy.

The parties filed cross-motions for summary judgment, asking the court to decide whether the administrative decision was supported by substantial evidence and used proper legal standards. The court reviewed the administrative record under 42 U.S.C. § 405(g).

Issues and rulings

Hearing notice and due process

Sanchez argued that he did not receive adequate notice of the issues to be decided at the administrative hearing because the record referred to a continuing disability review and other possible benefits proceedings. The court rejected this argument. Although the record contained unexplained references to a continuing disability review, the hearing notice identified Sanchez’s June 2014 application for Title II child’s insurance benefits. The court found no indication that Sanchez was confused about the benefits at issue or that he suffered identifiable prejudice. It found no error on this issue.

Medical opinions

The court found several errors in the administrative law judge’s treatment of medical evidence:

- The administrative law judge considered psychologist Cecilia M. Hardey’s report but did not state what weight he gave it. Because Hardey’s report was the only psychological evaluation performed before Sanchez turned 22, the court found that the omission was not harmless. - The administrative law judge did not mention or evaluate the opinions of state-agency psychologists V. Meenakshi and D. Lucila. Their reports identified several moderate limitations, including limitations in understanding and remembering detailed instructions, maintaining concentration, completing a normal workday, and working at a consistent pace. The court found that the failure to address these opinions was not harmless. - The court found that the administrative law judge did not provide sufficient specific and legitimate reasons for giving little weight to psychologist Maria Kerosky’s opinion. In particular, the court rejected the reason that Kerosky had examined Sanchez only once because that criticism applied equally to the other examining psychologists. - The court found no error in the administrative law judge’s treatment of psychologist Faith Tanner’s opinion. The administrative law judge gave Tanner’s opinion great weight and, in the court’s view, did not improperly ignore or selectively rely on her findings. - The court rejected Sanchez’s argument that the administrative law judge was required to obtain testimony from a medical expert. Although the court found that the medical opinions had not been properly evaluated, it found no basis to conclude that the administrative law judge improperly substituted his own medical judgment for that of a medical expert.

Listed impairments

The administrative law judge found that Sanchez’s mental impairments did not meet or medically equal the requirements of Listings 12.04, 12.05, 12.08, or 12.11. The court rejected Sanchez’s conclusory argument that the administrative law judge failed to consider the combined effects of his bipolar disorder and learning disability.

However, the court found that the administrative law judge erred in analyzing the functional criteria for Listings 12.04, 12.08, and 12.11 because he had not properly evaluated all of the medical-source opinions. The court also found error in the analysis of Listing 12.05, which concerns intellectual disorder. The administrative law judge relied on Tanner’s explanation that Sanchez’s lower adaptive and academic scores might be related to mental illness and to others performing tasks for him. But Tanner had not stated that Sanchez’s IQ score was invalid or inaccurate. The court therefore found that the administrative law judge improperly questioned the IQ scores on that basis and had not shown that the conclusion was supported by substantial evidence.

Sanchez’s reported symptoms

The court upheld the administrative law judge’s assessment of Sanchez’s statements about the severity and effects of his symptoms. The administrative law judge had discussed Sanchez’s daily activities, education records, medical records, and other evidence, and had identified inconsistencies that supported partially discounting his statements. The court found those reasons specific, clear, convincing, and supported by substantial evidence.

Work-capacity finding

The administrative law judge found that Sanchez could perform a full range of work at all exertional levels, subject to a limitation on how often he could respond appropriately to supervisors, coworkers, and the public. Because the administrative law judge had not properly evaluated all of the medical-source statements, the court could not determine that this residual functional capacity—the most a person can do despite limitations—was supported by substantial evidence. The court did not decide whether the questions posed to the vocational expert accurately reflected Sanchez’s limitations because the work-capacity finding itself required further consideration.

Statements from family and other witnesses

Sanchez challenged the decision to give little weight to statements from Kiva Brazington, Kimberlie Lowe, Lisa Fortune, Colleen S. Congress, and Rain Johnson. The court found that the administrative law judge did not provide a valid reason for rejecting the statements based on Tanner’s report. Nevertheless, it found that the administrative law judge had other adequate reasons for discounting these statements, including their similarity to Sanchez’s statements and inconsistencies with the medical record. The court therefore found no reversible error in the treatment of the witness statements.

Disposition

The court stated that it was not clear that Sanchez would necessarily be found disabled if all the evidence were properly evaluated. It therefore remanded the matter for further proceedings rather than ordering an award of benefits. On remand, the administrative law judge must properly evaluate the medical-source statements and may need to reconsider the listed-impairment analysis, Sanchez’s residual functional capacity, and whether he can work.

The court granted in part and denied in part Sanchez’s motion for summary judgment, granted in part and denied in part the Commissioner’s cross-motion for summary judgment, and remanded the matter for further proceedings consistent with the order. Judge Virginia K. Demarchi directed the clerk to enter judgment and close the file.