Adam P. v. O'Malley

Background

Seth Adam P. applied for Supplemental Security Income in October 2019, alleging disability beginning May 24, 2012. The Social Security Administration denied the application initially and on reconsideration. After a hearing, Administrative Law Judge Laura Michalec Olszewski denied the application on May 22, 2023. The Appeals Council denied review on February 2, 2024, making the administrative law judge’s decision the Commissioner’s final decision.

The administrative law judge found that Seth Adam P. had severe schizoaffective disorder, substance use disorder, bipolar disorder, generalized anxiety disorder, post-traumatic stress disorder, and degenerative disc disease of the lumbar spine. But the judge found that he did not have an impairment meeting the agency’s listed-impairment requirements. The judge determined that he could perform a limited range of light work, subject to restrictions on climbing, balancing, stooping, kneeling, crouching, crawling, stress, task complexity, decision-making, workplace changes, and interaction with others. Although he could not return to his past work as a carpenter, the judge found that other jobs existed in significant numbers that he could perform.

Arguments and Analysis

Seth Adam P. moved for judgment on the pleadings, asking the court to reverse the administrative decision. He raised five principal arguments: that the administrative law judge erred at the second step of the disability analysis; failed to include a further limitation on stooping; failed to develop the administrative record; improperly evaluated medical opinions; and improperly evaluated his reported symptoms.

The court reviews a Social Security decision to determine whether it is supported by substantial evidence and whether the Commissioner applied the correct legal standard. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

On the step-two issue, the court found no error. Seth Adam P. argued that intellectual disability and antisocial personality disorder should also have been found severe. The court noted that he had not alleged those conditions in his application or hearing testimony and had not identified evidence showing that they caused additional work-related limitations. The administrative law judge had considered his mental impairments and included mental restrictions in the residual functional capacity, or the most he could still do in a work setting.

On stooping, the court found that the administrative law judge’s limitation allowing occasional stooping was supported by the medical evidence. One consulting examiner found no impairment in stooping, and another found only mild limitations involving squatting, bending, stooping, kneeling, and lifting.

The court also rejected the argument that the administrative law judge failed to develop the record. Seth Adam P. sought additional educational records, but the court found that the request was conclusory and did not identify the records specifically or explain how they would materially change the outcome. The record already contained extensive information about his mental and social functioning, including two consulting psychiatric evaluations. The administrative law judge had also kept the record open after the hearing so that counsel could submit additional evidence.

Regarding the medical opinions, the court upheld the administrative law judge’s decision not to find persuasive the marked limitations assessed by Dr. Konstantinos Tsoubris. The court found those limitations inconsistent with the opinions of Dr. Alison Murphy and non-examining state-agency physicians, who assessed generally moderate mental limitations. The administrative law judge incorporated corresponding restrictions into the residual functional capacity, including low-stress work, simple and routine tasks, limited decision-making and workplace changes, and only occasional social interaction.

The court likewise upheld the evaluation of the physical opinions. Although an examination showed limited lumbar-spine flexion, the consulting examiners found no or only mild limitations in relevant physical activities. The administrative law judge also considered MRI evidence of disc disease and Seth Adam P.’s reports of pain by limiting him to a reduced range of light work.

Finally, the court found that the administrative law judge reasonably evaluated Seth Adam P.’s reported symptoms. The administrative law judge accepted that his impairments could cause the alleged symptoms but found that his statements about their intensity and limiting effects were not entirely consistent with the record. The court cited the treatment notes, clinical assessments, medical opinions, and activities of daily living as adequate support for that conclusion.

Ruling

Judge Gary R. Jones denied Seth Adam P.’s motion for judgment on the pleadings. The court granted the Commissioner judgment on the pleadings, dismissed the case, directed the Clerk to enter judgment for the Commissioner, and directed the Clerk to close the file.