Jessica P. v. Commissioner of the Social Security Administration
- Andrew Krause
- 7:24-cv-04834
- U.S. District Court · Southern District of New York
- 22
In Jessica P. v. Commissioner, Judge Krause denied remand, upholding the finding that medical improvement ended Jessica P.’s disability and permitted sedentary work.
Jessica P., whose disability benefits had been terminated, and the Commissioner of the Social Security Administration.
What happened
Jessica P. asked the court to review the Social Security Administration’s decision ending her disability benefits. She had previously been found disabled, but after a continuing review, an administrative law judge found that her disability ended on January 1, 2022.
Jessica P. argued that she still could not do sedentary work and challenged the jobs identified by a vocational expert. The Commissioner argued that the administrative law judge’s decision was supported by substantial evidence, including medical examinations, treatment records, testimony, and medical opinions.
Judge Andrew E. Krause denied Jessica P.’s motion for remand. He held that the administrative law judge properly found medical improvement, that Jessica P. could perform sedentary work and her past relevant work, and that any problems with the additional job findings did not require a remand. The court directed entry of judgment for the Commissioner and closure of the case.
The detailed version
- Jessica P. v. Commissioner of the Social Security Administration · No. 7:24-cv-04834
- Andrew Krause
- Sept. 2, 2025
Background
Jessica P. brought this action under 42 U.S.C. § 405(g) seeking review of the Commissioner’s final decision ending her disability insurance benefits. In 2018, an administrative law judge found that she had been disabled since November 21, 2014, based on impairments including a surgically repaired left hip labral tear, migraine headaches, endometriosis, and interstitial cystitis. That judge stated that medical improvement was expected with treatment and recommended a continuing disability review.
After that review, the Social Security Administration initially determined that Jessica P.’s disability ended on January 4, 2022. Following reconsideration and a hearing, Administrative Law Judge Kieran McCormack issued a decision finding that her disability ended on January 1, 2022, and that she had not become disabled again. The Appeals Council denied review, making the administrative law judge’s decision the Commissioner’s final decision.
Administrative Law Judge’s Decision
The administrative law judge applied the eight-step process used to determine whether a person previously found disabled remains eligible for benefits. He found that, since January 1, 2022, Jessica P. had a history of a left hip labral tear, a right hip labral tear with preserved cartilage, and a lumbar-disc protrusion, but that these impairments did not meet or equal a listed impairment.
The administrative law judge found medical improvement because the severity of Jessica P.’s impairments had decreased. The decision cited her normal gait, conservative treatment of pain, lack of surgery or emergency-room visits during the relevant period, and examinations in 2021, 2022, and 2023 that did not show abnormal findings. The judge determined that the improvement was related to her ability to work and that she still had severe physical impairments, but not impairments preventing all work.
The administrative law judge found that Jessica P. had the residual functional capacity—the most she could still do despite her impairments—to perform sedentary work, with occasional climbing, balancing, stooping, kneeling, crouching, and crawling. He also found that she could perform her past relevant work as an eligibility worker and case worker. As an alternative finding, he determined that she could perform work as a document preparer, assembly inspector, or polisher.
Arguments and Court’s Analysis
Jessica P. argued that she remained unable to perform sedentary work and remained disabled. She also argued that assembly-inspector and polisher jobs were not available in significant numbers and that the document-preparer job was obsolete. The Commissioner maintained that the administrative law judge applied the correct legal standards and supported the decision with substantial evidence.
The court explained that its review was limited to whether the Commissioner applied the correct legal standards and whether the decision was supported by substantial evidence. The court does not decide disability from the beginning or reweigh the evidence when the record permits more than one reasonable interpretation.
The court concluded that substantial evidence supported the finding that Jessica P.’s pain did not prevent sedentary work. The record included normal gait and balance findings, reports of exercise and other activities, conservative pain treatment, and medical opinions supporting the residual-functional-capacity assessment. The court also upheld the administrative law judge’s evaluation of anxiety and other conditions, finding that the evidence did not establish disabling limitations.
The court rejected the challenge to the three additional jobs as a basis for remand. Because the administrative law judge had already properly found at the prior step that Jessica P. could perform her past relevant work, the later job analysis was unnecessary. Any error in that alternative analysis would therefore not require remand.
Disposition
Judge Andrew E. Krause denied Jessica P.’s motion for remand. The court held that there was no legal error in the administrative law judge’s decision and that the decision was supported by substantial evidence. The Clerk of Court was directed to enter judgment for the Commissioner and close the case.
Read the full 22-page opinion on CourtListener, the free public archive maintained by the Free Law Project.