Tria V. H. v. Colvin
- Katherine Menendez
- 0:23-cv-02979
- U.S. District Court · District of Minnesota
- 7
In Tria V. H. v. Colvin, Judge Menendez affirmed the denial of disability benefits, overruled the objection, and dismissed the case with prejudice.
Tria V. H.’s claim for disability benefits was denied, the Commissioner’s decision was affirmed, and the case was dismissed with prejudice. The Commissioner prevailed on the court’s review.
What happened
In Tria V. H. v. Colvin, Tria V. H. challenged the denial of her application for disability benefits. A magistrate judge recommended denying her request and affirming the Social Security Commissioner’s decision.
Tria V. H. argued that the administrative law judge did not include all of Dr. Barron’s stated limits on workplace interactions, including that interactions should be very brief and infrequent. The court concluded that the administrative law judge reasonably included a limit to superficial interactions and was not required to copy the medical opinion word for word.
Judge Menendez overruled Tria V. H.’s objection, accepted the recommendation, denied her request for relief, granted the Commissioner’s request for relief, affirmed the benefits denial, and dismissed the case with prejudice.
The detailed version
- Tria V. H. v. Colvin · No. 0:23-cv-02979
- Katherine Menendez
- Jan. 10, 2025
Background
Tria V. H. brought this action challenging the Commissioner of Social Security’s denial of her application for disability benefits. On November 25, 2024, Magistrate Judge Shannon G. Elkins recommended denying relief and affirming the Commissioner’s decision. Tria V. H. timely objected to that recommendation.
Issue
Tria V. H. argued that the administrative law judge (ALJ) improperly evaluated the opinion of Dr. Barron, a state-agency psychologist who conducted a consultative examination. Dr. Barron stated that Tria V. H. was marginally able to interact with the public and could have very brief, infrequent, and superficial interactions with coworkers and supervisors.
The ALJ found Dr. Barron’s opinion generally persuasive and determined that Tria V. H.’s residual functional capacity (RFC)—the most she could still do in a work setting—allowed only superficial interactions with others, such as taking basic instructions, relaying information, and transferring materials. Tria V. H. argued that the ALJ should also have expressly included the terms “very brief” and “infrequent” and should have explained their omission.
Court’s analysis
The court reviewed the disputed portions of the recommendation anew and reviewed the undisputed portions for clear error. It agreed with Magistrate Judge Elkins that the ALJ did not commit reversible error.
The court explained that the ALJ was not required to adopt a medical opinion’s limitations word for word, even after finding the opinion persuasive. The court also concluded that the ALJ’s limitation to superficial interactions was not inconsistent with Dr. Barron’s opinion. Interactions limited to taking basic instructions, relaying information, and transferring materials would likely be brief and infrequent in a workplace setting.
The court further concluded that the ALJ adequately explained the RFC assessment. The ALJ discussed why the RFC included a limitation to superficial interactions, considered the evidence about Tria V. H.’s ability to interact with others, and accounted for Dr. Barron’s opinion to the extent it was consistent with the full record. The court rejected the argument that the ALJ had to separately list and reject, or expressly reconcile, every possible limitation in Dr. Barron’s opinion.
Disposition
The court ordered that:
- Tria V. H.’s objection was overruled.
- The Report and Recommendation was accepted.
- Tria V. H.’s request for relief was denied.
- The Commissioner’s request for relief was granted.
- The Commissioner’s decision denying benefits was affirmed.
- The matter was dismissed with prejudice.
Judge Katherine Menendez directed that judgment be entered accordingly.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.