Jennifer L. v. O'Malley

Background

Jennifer L. sought judicial review of the Commissioner of the Social Security Administration’s decision denying her application for disability benefits. On June 27, 2024, Magistrate Judge Tony N. Leung issued a report and recommendation advising that Jennifer L.’s request for relief be denied, the Commissioner’s request for relief be granted, and the benefits denial be affirmed. Jennifer L. timely objected.

Issues and analysis

Jennifer L. challenged the administrative law judge’s treatment of opinions from mental-health professionals who examined or evaluated her. Those professionals described limits involving both the frequency and the quality of her interactions with other people, including “occasional” and “superficial” interactions. The administrative law judge’s residual functional capacity assessment limited Jennifer L. to occasional interactions with coworkers and the public and occasional contact with supervisors, but did not separately use the word “superficial.”

The court held that the administrative law judge was not required to copy the medical opinions word for word. Instead, the question was whether substantial evidence supported the residual functional capacity assessment. The court relied on Eighth Circuit decisions stating that “occasional” interactions did not necessarily conflict with opinions describing “superficial” interactions. It also noted that “superficial” is not defined in the Social Security regulations or the other sources discussed in the opinion, and that the professionals had not explained the term in a way that clearly conflicted with the administrative law judge’s assessment.

The court further found that the administrative law judge adequately explained the nonphysical limits included in the assessment by discussing Jennifer L.’s reported difficulties, mental-health symptoms, and examination findings. Jennifer L. did not argue in her objections that those findings lacked substantial evidence. She also did not object to the recommendation’s conclusion concerning the evaluation of her statements about the intensity, persistence, and limiting effects of her symptoms. The court therefore reviewed that issue for clear error and found none.

Disposition

Judge Menendez ordered that the report and recommendation be accepted; Jennifer L.’s objection be overruled; Jennifer L.’s request for relief be denied; and the Commissioner’s request for relief be granted. The court affirmed the Commissioner’s decision denying the application for benefits and dismissed the matter with prejudice. The opinion text’s caption identifies the defendant as the Commissioner of the Social Security Administration, although the supplied case name refers to O’Malley.