Yrene L.E. v. Commissioner of Social Security
- Jones
- 1:24-cv-06481
- U.S. District Court · Southern District of New York
- 13
In Yrene L.E. v. Commissioner, Magistrate Judge Jones granted judgment for Yrene L.E. and remanded for further proceedings.
Dinorah Martha Yrene L.E., whose denial of disability benefits was remanded for further administrative proceedings; the Commissioner must reconsider the evidence as directed by the court.
What happened
In Yrene L.E. v. Commissioner of Social Security, the court reviewed the denial of Dinorah Martha Yrene L.E.’s application for disability benefits. The Administrative Law Judge found that her physical and mental impairments were not severe and denied benefits.
Yrene L.E. argued that the Administrative Law Judge wrongly rejected the opinions of four physicians about her physical limitations. The court agreed that the Administrative Law Judge failed to consider the consistency among those opinions and should have sought clarification or additional records before finding the impairments non-severe.
Judge Gary R. Jones granted Yrene L.E.’s motion for judgment on the pleadings and remanded the matter for further administrative proceedings. The Clerk was directed to enter final judgment for Yrene L.E. and close the case.
The detailed version
- Yrene L.E. v. Commissioner of Social Security · No. 1:24-cv-06481
- Jones
- June 30, 2025
Background
Dinorah Martha Yrene L.E. applied for Disability Insurance Benefits in September 2020, alleging that she became disabled on September 14, 2019. The Social Security Administration denied the application initially and on reconsideration. After a hearing, Administrative Law Judge Flor M. Suarez denied benefits on October 11, 2023. The Appeals Council denied review on July 8, 2024, making the Administrative Law Judge’s decision the Commissioner’s final decision.
The Administrative Law Judge found that Yrene L.E. had several medically determinable physical and mental impairments, including spinal conditions, eye conditions, venous insufficiency, a history of left-knee surgery, anxiety and depressed mood, and a pain disorder. But the Administrative Law Judge concluded that these impairments, alone or together, did not significantly limit her ability to perform basic work activities as of December 31, 2021, her date last insured. The Administrative Law Judge therefore found that the impairments were not severe and that Yrene L.E. was not disabled during the relevant period.
Yrene L.E. sought review under 42 U.S.C. §§ 405(g) and 1383(c)(3), arguing that the Administrative Law Judge erred at step two of the disability-evaluation process. The Commissioner opposed her motion and requested judgment on the pleadings.
Court’s analysis
At step two, the Administrative Law Judge must determine whether a medically determinable impairment significantly limits a claimant’s physical or mental ability to perform basic work activities. The court explained that this step is intended to screen out only claims involving slight abnormalities with no more than a minimal effect on the ability to work.
The court held that the Administrative Law Judge’s finding about Yrene L.E.’s physical impairments could not be sustained. Four physicians provided functional assessments indicating that she had work-related limitations. State-agency physicians Dr. S. Jacob and Dr. C. Levit identified a severe abnormality of a major joint and assessed limitations involving lifting, standing or walking, climbing, crouching, crawling, kneeling, and overhead reaching with the left arm. Consultative examiner Dr. Ram Ravi diagnosed left shoulder and knee pain, found limitations involving bending, overhead reaching, pushing, pulling, lifting, and carrying, and recommended avoiding squatting. Treating provider Dr. Mihail Medvedovsky diagnosed lumbar radiculopathy and assessed more restrictive limitations involving lifting, sitting, standing, walking, breaks, and reaching.
The Administrative Law Judge found all four assessments unpersuasive, relying mainly on what she viewed as limited treatment records and examinations showing normal strength. The court ruled that she improperly considered the opinions separately instead of addressing their important consistency, particularly their shared conclusion that Yrene L.E. had limitations affecting lifting, carrying, and reaching. The court also concluded that the Administrative Law Judge should have sought clarification from Dr. Ravi about the term “moderate” and additional treatment records or explanation from Dr. Medvedovsky before rejecting the medical evidence.
Disposition
The court granted Yrene L.E.’s Motion for Judgment on the Pleadings. It remanded the matter for further administrative proceedings consistent with the decision, ordered the Clerk to enter final judgment in Yrene L.E.’s favor, and directed the Clerk to close the file. The remand required proper consideration of the evidence concerning the extent of the limitations caused by Yrene L.E.’s physical impairments; the court did not itself award benefits or decide that she was disabled.
Judge Gary R. Jones signed the Decision and Order on June 30, 2025.
Read the full 13-page opinion on CourtListener, the free public archive maintained by the Free Law Project.