Ciara T. C. v. Dudek

Background

Ciara T. C. sought review under 42 U.S.C. § 405(g) of the Acting Commissioner of Social Security’s final decision denying her application for Disability Insurance Benefits. She alleged that she had been disabled since December 4, 2020. The Social Security Administration denied the application initially and on reconsideration. After a hearing, an administrative law judge issued an unfavorable decision, and the Appeals Council denied review.

The administrative law judge found severe impairments including degenerative disc disease, ankylosing spondylitis, depression, anxiety, and post-traumatic stress disorder. The judge determined that Ciara T. C. retained the capacity to perform light work with restrictions on climbing, postural activities, vibration exposure, task complexity, and interaction with the public, coworkers, and supervisors. Based on vocational-expert testimony, the judge found that she could perform jobs including marker, routing clerk, mail clerk, preparer, touch-up screener or printed circuit board assembler, and film touch-up inspector.

Issues and Analysis

Ciara T. C. raised five challenges. She argued that the administrative law judge improperly evaluated Dr. Kathryn Lombardo’s treating-psychiatrist opinion; failed to classify chronic pain syndrome as a severe impairment; improperly discounted her testimony about her symptoms and limitations; relied on unsupported vocational-expert testimony; and used hypothetical questions that did not include all of her limitations.

Dr. Lombardo’s opinion. Dr. Lombardo assessed extreme limitations in 18 of 20 areas, a marked limitation in one area, and a moderate limitation in one area. She opined that Ciara T. C. could not work regularly for 40 hours per week and would miss at least four workdays per month. The court held that the administrative law judge used the proper regulatory framework by considering supportability and consistency. The judge found the opinion unsupported because it did not cite supporting medical records and inconsistent with other records, including treatment notes describing Ciara T. C. as alert, cooperative, clear-headed, and able to demonstrate good judgment. The court concluded that substantial evidence supported finding Dr. Lombardo’s opinion unpersuasive.

Chronic pain syndrome. The court found that the record linked chronic pain syndrome closely to Ciara T. C.’s spinal conditions, including degenerative disc disease and ankylosing spondylitis. It therefore found no reversible error in the failure to list chronic pain syndrome separately as a severe impairment. The court also concluded that the administrative law judge considered the condition’s functional effects when limiting Ciara T. C. to light work and adding postural and other restrictions based on back and joint pain.

Testimony about symptoms. The court held that the administrative law judge properly considered Ciara T. C.’s testimony and the required factors, including her daily activities, treatment, medical findings, and functional limitations. The judge relied on evidence that she had not been recommended for surgery, had no disc herniation or stenosis, lacked severe loss of motion or significant neurological deficits, and had activities including preparing meals, doing housework with breaks, walking her dog, shopping, and socializing. The court also cited records concerning her mental-health treatment, education, work history, cognitive functioning, and ability to handle finances and medical care. It concluded that the evaluation was supported by substantial evidence.

Available work. The court upheld the administrative law judge’s reliance on the vocational expert’s testimony. The expert identified representative light-work jobs and, in response to a sedentary-work hypothetical, identified three additional representative jobs. The expert testified that the jobs did not involve public-facing activity and involved only brief and superficial interaction with coworkers and supervisors. The court rejected Ciara T. C.’s challenge based on other sources suggesting different levels of social interaction, finding that the expert’s testimony, education, experience, and use of the Dictionary of Occupational Titles provided substantial evidence.

Hypothetical questions. Because the court upheld the residual functional capacity assessment, it also held that the hypothetical questions based on that assessment properly accounted for Ciara T. C.’s proven impairments. The court found no error in the administrative law judge’s reliance on the vocational expert’s answers.

Ruling

The court affirmed the Commissioner’s denial of Disability Insurance Benefits. The order states that Ciara T. C.’s request for reversal was DENIED, the Commissioner’s request for affirmance was GRANTED, and judgment was to be entered accordingly.