Darin G. v. Dudek

Background

Darin G. applied for disability insurance benefits and supplemental security income on November 12, 2021. He alleged that his disability began on January 1, 2018, later amending that date to January 1, 2019. After a hearing, an administrative law judge found that Darin G. had several impairments, including degenerative disc disease, degenerative joint disease, major depressive disorder, generalized anxiety disorder, attention deficit hyperactivity disorder, and personality disorder.

The administrative law judge found that Darin G. could perform light work, could not perform his past relevant work, but could perform other jobs existing in significant numbers in the national economy. The judge therefore found that Darin G. was not disabled during the relevant period. In evaluating the medical evidence, the judge found the opinions of Darin G.’s treating physician, Dr. Misty Eliason, unpersuasive. Those opinions included limitations involving unscheduled breaks and absences from work.

The Appeals Council denied review. In this action, Darin G. and the Commissioner filed cross-motions for summary judgment, which ask the court to decide the case based on the administrative record. Magistrate Judge Tony L. Leung recommended affirming the Commissioner’s decision, concluding that the administrative law judge adequately evaluated Dr. Eliason’s opinions and reached a decision supported by substantial evidence. Darin G. objected to that recommendation.

Issue

Darin G. argued that the administrative law judge failed to evaluate Dr. Eliason’s opinions as required by 20 C.F.R. § 404.1520c, particularly the factors of supportability and consistency. Supportability concerns whether objective medical evidence and explanations support a medical opinion. Consistency concerns whether the opinion agrees with evidence from other medical and nonmedical sources.

Analysis

The court held that the administrative law judge was not required to use the specific words “supportability” and “consistency.” The court found sufficient evidence that the judge considered both factors. The judge noted that Dr. Eliason had known Darin G. for only part of the relevant period, that some of her conclusions were not supported by or consistent with the record, and that test results showing only mild to moderate anxiety were inconsistent with part of her opinion.

Applying the substantial-evidence standard under 42 U.S.C. § 405(g), the court concluded that the administrative law judge’s denial of benefits was supported by substantial evidence. The court agreed with the magistrate judge’s recommendation to affirm the Commissioner’s decision.

Disposition

The court overruled Darin G.’s objection, adopted the Report and Recommendation, denied Darin G.’s request for relief, granted the Commissioner’s request for relief, and affirmed the Commissioner’s decision. The court directed that judgment be entered accordingly.