Sage P. J. v. Dudek

Background

Sage P. J. sought judicial review under 42 U.S.C. § 405(g) of the Acting Commissioner of Social Security’s final decision denying applications for disability insurance benefits and supplemental security income. Sage P. J. alleged disability beginning May 27, 2021, based on autism, chronic depression, anxiety, panic disorder, and attention deficit hyperactivity disorder.

After an administrative hearing, the administrative law judge found that Sage P. J. had not engaged in substantial gainful activity since the alleged onset date and had several severe mental impairments. The administrative law judge determined that the impairments did not meet or equal a listed impairment. The administrative law judge assessed a residual functional capacity—the most a person can still do despite limitations—allowing work at all exertional levels, with occasional interaction with coworkers and the public and ordinary levels of supervision. The administrative law judge found that Sage P. J. could not perform past work as a customer service representative but could perform jobs including laundry worker, store laborer, and hand packager. The administrative law judge therefore found Sage P. J. not disabled. The Appeals Council denied review.

Issues and analysis

Sage P. J. argued that the administrative law judge improperly evaluated opinions from psychotherapist Julie Beckmann and psychiatrist Joshua Baruth. The court explained that the administrative law judge had to consider the opinions’ supportability and consistency, among other factors. The court found that the administrative law judge adequately addressed those factors and reasonably concluded that the opinions were not persuasive because they were not supported by the providers’ treatment records, were inconsistent with other evidence, and described limitations more severe than reflected in the generally conservative treatment and mental-status findings.

The court also rejected the challenge to the evaluation of Sage P. J.’s reported symptoms. It concluded that the administrative law judge properly considered daily activities, medical findings, medication effectiveness, treatment, and Sage P. J.’s own statements. The court held that substantial evidence supported the conclusion that the reported intensity, persistence, and limiting effects of the symptoms were inconsistent with the record, while noting that the residual functional capacity nevertheless included limits on interactions with coworkers and the public.

The court further held that the administrative law judge did not improperly omit autism-related sensory-dysregulation symptoms from the residual functional capacity. The record showed that occupational therapy helped Sage P. J. develop coping techniques and routines, that Sage P. J. reported her routines and sensory systems were regulated, and that she was discharged from occupational therapy after meeting her goals. The court also rejected the challenge to omitting time-off-task, unscheduled-break, and excessive-absence restrictions because the opinions supporting those restrictions had properly been found unpersuasive, and Sage P. J. had not identified or explained how other evidence established specific amounts of such limitations.

Disposition

The court denied Sage P. J.’s Motion for Summary Judgment, granted the relief requested in the Commissioner’s Brief, and affirmed the Commissioner’s final decision. Judgment was ordered to be entered accordingly.