Medina Reyes v. Commissioner of Social Security

Background

Daniel Medina Reyes sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying his application for Disability Insurance Benefits and Supplemental Security Income. He sought benefits for a closed period from May 26, 2016, through January 1, 2018. The administrative law judge, Elias Feuer, found that Medina Reyes was not disabled during that period. The Appeals Council denied review.

Before the district court, Medina Reyes moved for judgment on the pleadings, meaning he asked the court to decide the case based on the administrative record and the parties’ written submissions. The Commissioner filed a cross-motion for the same relief.

Issues and analysis

Medina Reyes argued that the administrative law judge failed to properly consider his bipolar disorder at the third step of the disability analysis, improperly assessed his residual functional capacity, and incorrectly decided at the fifth step that he could perform other work.

The court rejected the challenge to the step-three analysis. Although the administrative law judge did not expressly discuss bipolar disorder when addressing the first part of Listing 12.04, the court treated that part of the listing as satisfied and concluded that the judge adequately evaluated the remaining requirements. The court found substantial evidence supporting the conclusion that Medina Reyes did not have the required marked or extreme mental limitations.

The court also upheld the residual functional capacity finding. The administrative law judge limited Medina Reyes to sedentary work, with additional limits to simple, routine, and repetitive tasks; simple work-related decisions; occasional interaction with coworkers, supervisors, and the public; and use of a cane for walking but not standing. The court concluded that substantial evidence supported those findings. It also upheld the administrative law judge’s decision to give little weight to opinions from treating providers Dr. Terrelonge and Dr. Liriano because those opinions conflicted with their treatment notes and other evidence. The court rejected arguments concerning alleged white matter disease, medication side effects, concentration and adaptation limits, foot controls, stooping, cane use, and English-language ability as challenges to the residual functional capacity finding.

The court did find legal error at step five. The administrative law judge relied on the Medical-Vocational Guidelines and stated, without sufficient explanation, that Medina Reyes could meet the mental demands of work. But Medina Reyes had both exertional limits, including a restriction to sedentary work, and non-exertional limits involving task complexity and workplace interactions. The court held that the administrative law judge therefore needed either to carefully explain why those non-exertional limits had no significant effect on the range of sedentary work or to obtain testimony from a vocational expert. The judge did neither and improperly relied on Social Security Ruling 85-15, which the court found did not apply to this combination of exertional and non-exertional limits.

The court did not reach Medina Reyes’s additional arguments about the specific Medical-Vocational Rule used, English literacy, or the effect of his cane at step five because the identified error already required a remand.

Disposition

Judge Andrew E. Krause granted Medina Reyes’s motion for judgment on the pleadings and denied the Commissioner’s cross-motion. The court remanded the matter to the Social Security Administration for further administrative proceedings under sentence four of 42 U.S.C. § 405(g), directed the Clerk of Court to enter judgment in Medina Reyes’s favor, and did not award benefits. The opinion also states that the court declined to decide whether any hearing on remand should be held before a different administrative law judge.