Medranda v. Kijakazi

Background

Evelyn Medranda sought review under Section 205(g) of the Social Security Act of a May 3, 2023 decision denying her applications for Supplemental Security Income and Disability Insurance Benefits. The administrative law judge found that Ms. Medranda had several severe impairments, including bipolar disorder, depressive disorder, anxiety disorder, fibromyalgia, chronic fatigue syndrome, cervical radiculopathy, and breast cancer. The judge determined that she could not perform her past relevant work as a hairstylist or child monitor, but retained the residual functional capacity to perform light work with additional physical and mental limitations.

The administrative law judge nevertheless found at the fifth step of the disability analysis that Ms. Medranda could perform jobs existing in significant numbers in the national economy. The decision relied in part on testimony from a vocational expert. The expert identified hand packer, production worker, and production inspector as representative jobs within broader standard occupational classification categories. The expert provided job-number estimates for the broader categories but did not clearly provide estimates for the three specific Dictionary of Occupational Titles positions. Ms. Medranda’s attorney challenged the reliability of those estimates during the hearing.

Parties’ Positions

Ms. Medranda argued that the fifth decision was unsupported by substantial evidence and contained legal errors. She requested a remand solely for calculation of benefits, pointing to the lengthy history of administrative proceedings. The Commissioner agreed that a remand was appropriate but argued that the case should return to the agency for further proceedings because the record did not establish disability conclusively and further development was needed at step five.

The Commissioner also suggested that the administrative law judge had made errors in evaluating medical-opinion evidence. Ms. Medranda stated in reply that she did not challenge the finding that she could not perform her past relevant work. The court therefore treated step five as the only disputed issue for purposes of remand.

Court’s Analysis

The court explained that judicial review asks whether the administrative law judge applied the correct legal standard and whether the decision is supported by substantial evidence. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion. At step five, the Commissioner bears the burden of showing that jobs the claimant can perform exist in significant numbers in the national economy.

The court held that the administrative law judge failed to resolve ambiguities in the vocational expert’s testimony and failed to obtain accurate estimates for the specific jobs identified. The court concluded that a more complete record might support the Commissioner’s decision. Because reliable vocational-expert testimony was missing, the court held that it could not order an immediate calculation of benefits or conduct its own analysis of available job types and numbers.

The court also held that the length of the proceedings, although distressing, did not by itself justify ordering benefits. Further proceedings were appropriate because the remaining issue could be addressed by obtaining accurate job estimates and determining whether the identified positions existed in significant numbers during the relevant period.

Disposition

Ms. Medranda’s motion was GRANTED IN PART and DENIED IN PART. The Commissioner’s motion was also GRANTED IN PART and DENIED IN PART. The action was remanded for further proceedings consistent with the opinion and order. Proceedings before the administrative law judge must be completed within 120 days of September 6, 2024. If the administrative law judge’s decision is appealed, the Commissioner’s final decision must be rendered within 60 days of that appeal. The court stated that if those deadlines are not met, a calculation of benefits owed to Ms. Medranda based on her alleged onset date must be made immediately. The Clerk was directed to close the motion and the action.