Monique J. v. Commissioner of Social Security

Background

Kerissa Monique J. applied for Social Security Disability Insurance benefits in November 2021, alleging that her disability began on October 19, 2019. The Social Security Administration denied the application initially and again on reconsideration. After a hearing, Administrative Law Judge Timothy Belford denied the claim on January 4, 2024. The Appeals Council declined further review, making the Administrative Law Judge’s decision the Commissioner’s final decision.

The Administrative Law Judge found that, by March 31, 2023—the last date on which Monique J. was insured—she had severe impairments involving her spine, left shoulder, anxiety, depression, and schizophrenia. But the Administrative Law Judge found that her impairments did not meet or equal a listed impairment. He determined that she could perform light work with limits on reaching and exposure to pulmonary irritants. He also limited her to simple, routine tasks, occasional workplace changes, no public interaction, and only occasional interaction with coworkers. Although she could not return to her past work, the Administrative Law Judge found that other jobs existed in significant numbers in the national economy that she could perform.

Arguments and analysis

Monique J. asked for judgment on the pleadings, meaning a decision based on the court filings and the administrative record. She argued that the Administrative Law Judge improperly evaluated the opinions of her treating mental-health providers and therefore reached an unsupported residual functional capacity finding. She also challenged the evaluation of her subjective complaints, including her testimony about auditory hallucinations and other limitations.

The court rejected the challenge to the medical-opinion analysis. The Administrative Law Judge found psychiatrist Dr. Richard Gersh’s opinion only partially persuasive and psychiatrist Dr. Carol Kessler’s opinion unpersuasive. Those providers had described extreme or marked mental limitations. The court concluded that the Administrative Law Judge reasonably discounted those more restrictive assessments based on other medical opinions, including opinions from state-agency reviewers and a consultative examiner; generally unremarkable mental-status examinations; evidence that symptoms were managed with medication; and activities such as self-care, managing finances, going to movies and museums, and performing basic chores.

The court also found that the Administrative Law Judge did not ignore Monique J.’s mental-health limitations. Instead, he found moderate limitations in several areas and included corresponding restrictions in the residual functional capacity assessment, including simple routine work, limited workplace changes, no public contact, and occasional coworker interaction.

As to subjective complaints, the court explained that the Administrative Law Judge had to consider Monique J.’s statements along with the medical and other evidence but was not required to accept those statements without question. The Administrative Law Judge found that her impairments could reasonably produce the alleged symptoms but that her statements about their intensity, persistence, and limiting effects were not entirely consistent with the record. The court held that this conclusion was supported by a reasonable reading of the record and that there was no reversible error.

Disposition

Judge Gary R. Jones held that the Commissioner’s decision was supported by substantial evidence and applied the correct legal standard. The court DENIED Monique J.’s Motion for Judgment on the Pleadings (Docket No. 15) and DISMISSED the case. It directed the Clerk to enter final judgment in favor of the Commissioner and close the file. The opinion did not add a with-prejudice or without-prejudice qualifier.