Stephanie L. v. King

Background

Stephanie L. sought judicial review of the Social Security Commissioner’s final decision denying her application for supplemental security income. She filed the application on February 2, 2022, alleging disability based on lupus, high blood pressure, sciatica, prediabetes, high cholesterol, arthritis, migraines, neuropathy, and anxiety.

After a hearing, the administrative law judge found that Stephanie L. had severe lumbar degenerative disc disease, systemic lupus erythematosus, and migraines. The administrative law judge found that she had the residual functional capacity to perform light work, with limits on reaching, handling, fingering, exposure to extreme temperatures, climbing, crouching, crawling, and stooping. The administrative law judge concluded that she could perform her past work as a medical records clerk and other jobs, including merchandise marker, cashier, and housekeeping cleaner. The Appeals Council declined to review that decision.

Issues and Analysis

Stephanie L. moved for summary judgment, asking the court to remand the case. She argued that the administrative law judge improperly evaluated her subjective symptoms under Social Security Ruling 16-3p and failed to support the work-capacity finding with substantial evidence. The Commissioner argued that the administrative law judge reasonably evaluated the record and that substantial evidence supported the denial of benefits.

The court rejected Stephanie L.’s arguments. It concluded that the administrative law judge considered her testimony and medical history concerning lupus, back pain, and migraines. The court also found that the administrative law judge reasonably considered medical findings showing normal or largely normal gait, range of motion, strength, and examinations; her treatment history; her daily activities; and her efforts to find work. The court stated that the administrative law judge was not required to discuss each factor separately as long as the decision gave good reasons supported by substantial evidence.

The court also rejected Stephanie L.’s challenge to the residual functional capacity finding. It explained that the question was whether substantial evidence supported the administrative law judge’s decision, not whether some evidence supported a different result. The court concluded that the administrative law judge’s evaluation of her symptoms and work limitations met that standard.

Disposition

The court DENIED Stephanie L.’s Motion for Summary Judgment. It GRANTED the Commissioner’s request to affirm the administrative decision, CANCELLED the March 24, 2025 hearing, and DISMISSED WITH PREJUDICE the case. The order directed that judgment be entered accordingly.