Lisa M. v. O'Malley

- Title XVI application: Lisa M. argued that the administrative law judge failed to consider an application for Title XVI benefits. The court found no indication in the cited record that she had applied for Title XVI benefits; the cited document concerned Title II and related insurance benefits. - Date of last insured: Lisa M. argued that her insured status lasted until 2019 rather than

1. The court concluded that her earnings in 2014 and 2015 appeared to be back pay, and that her certified earnings record showed her insured status ended at the end of December
2. - Later medical records: The court acknowledged that medical evaluations after insured status expires can sometimes be relevant to the earlier condition. But Lisa M. cited nearly 500 pages of later records without explaining how most related to her condition before the end of
3. The court found no error in the administrative law judge’s treatment of those records. - Symptom testimony: Lisa M. argued that the administrative law judge did not give adequate reasons for rejecting her testimony. The court found that the administrative law judge reasonably relied on evidence that Lisa M.’s activities—including watching forensic science shows, playing computer games and poker, taking her husband to appointments, and helping with meals—were inconsistent with claimed problems with concentration. The administrative law judge also relied on a medical report that did not support Lisa M.’s report of mood swings. The court found no error. - Age criteria: Lisa M. argued that the administrative law judge should have used her age when the decision was made rather than her age on the date her insured status ended. The court relied on Social Security Ruling 83-10, which states that when insured status ends before adjudication, the relevant age is the claimant’s age on the date last insured. The court also noted that the administrative law judge relied on vocational-expert testimony rather than the medical-vocational profiles because Lisa M. had both physical and nonphysical limitations. - Dr. Dickey’s physical opinion: The court found that the administrative law judge did consider Dr. Dickey’s January 2016 opinion that Lisa M. could not walk for more than two hours or more than three blocks without rest or severe pain. The administrative law judge gave the opinion little weight because it conflicted with examination findings, including observations that Lisa M. walked to the examination room without assistance, had normal or relatively stable findings in later examinations, and had a normal gait in August
4. - Mental limitations: The court found that the administrative law judge considered the required areas of mental functioning and found mild or moderate limitations, rather than extreme or marked limitations. The administrative law judge relied on examination results, Lisa M.’s daily activities, reports that she interacted appropriately with others, and Dr. Dickey’s observations. The court concluded that Lisa M. had not identified an error in this analysis.