Reagies T. v. O'Malley

Background

Reagies T. was awarded childhood disability benefits because of autism beginning in 2009. In 2016, the Commissioner determined that he remained disabled as an adult. The Commissioner later conducted a continuing disability review and determined that Reagies T.’s condition had improved and that he was no longer disabled.

Reagies T. appealed the cessation of benefits. An administrative law judge held a hearing in April 2023, at which Reagies T. testified and was represented by an attorney. On June 12, 2023, the administrative law judge determined that Reagies T.’s medical condition had improved, that he had been able to work since January 1, 2021, and that his disability therefore ended as of that date. The Appeals Council denied review.

The administrative law judge found that Reagies T. had severe autism spectrum and anxiety disorders. The judge nevertheless found that these impairments did not meet or medically equal a listed impairment. The judge determined that Reagies T. had the residual functional capacity—the most he could still do despite his impairments—to perform work at all exertional levels, subject to restrictions involving workplace dangers, task complexity, workplace changes, decision-making, and interactions with the public and others. After considering vocational-expert testimony, the judge found that jobs existed in sufficient numbers in the national economy that Reagies T. could perform.

Arguments and analysis

The court reviewed the administrative decision to determine whether it was supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate to support the conclusion.

Reagies T. first argued that he was automatically disabled under Listing 12.10 for autism spectrum disorder. The court explained that the relevant paragraph B criteria required at least one extreme limitation or two marked limitations in specified areas of mental functioning. The administrative law judge found that Reagies T. had neither. The court concluded that Reagies T. did not identify how the judge erred in evaluating those areas, explain how the cited evidence showed an error, or provide legal authority supporting his assertions. The court also noted that an administrative law judge need not discuss every piece of submitted evidence and that the administrative law judge had referenced many of the records Reagies T. identified.

Reagies T. also argued that the administrative law judge did not adequately consider significant family and community support when determining his residual functional capacity. The court found that he did not identify record evidence supporting that argument and did not explain the relevance of the cases he cited. The court therefore concluded that he failed to meet his continuing burden to demonstrate that he was disabled.

Finally, Reagies T. argued that the administrative law judge gave too much weight to the 2021 opinions of Dr. Craig Barron and Dr. Craig Brown and improperly rejected opinions from Dr. Alford Karayusuf and Dr. Robin Councilman. The court found that Reagies T. did not identify a specific error in the administrative law judge’s analysis of the regulatory factors governing medical opinions. The administrative law judge had explained that Dr. Councilman’s findings were conclusory, inconsistent with other findings and records, and presented in a check-box opinion. The administrative law judge also relied on evidence that Reagies T.’s condition had improved since 2016, including Dr. Barron’s observation that Reagies T. no longer showed the same lack of understanding of basic concepts and questions observed by Dr. Karayusuf in 2016.

Ruling

Judge Magnuson concluded that substantial evidence supported the administrative law judge’s determination that Reagies T. was not disabled. The court ordered that Reagies T.’s motion for judgment be denied, the Commissioner’s motion for judgment be granted, and the matter be dismissed with prejudice.