Samantha T. v. Frank J. Bisignano

Background

Samantha T. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s decision denying her applications for child’s disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. She asked the court to reverse the decision and order immediate payment of benefits or, alternatively, require further administrative proceedings.

Samantha T. applied for child’s insurance benefits on September 27, 2021, and supplemental security income on February 28, 2022. After the applications were denied initially and on reconsideration, an administrative law judge held a hearing and received testimony from Samantha T. and a vocational expert. The administrative law judge denied the applications on June 17, 2024; that decision became the Commissioner’s final decision after the Appeals Council denied review.

The administrative law judge found that Samantha T. had not engaged in substantial gainful activity since her alleged onset date of April 30, 2017. The judge found severe impairments consisting of an eating disorder, obsessive-compulsive disorder, an anxiety disorder, a depressive disorder, and autism spectrum disorder. The judge concluded that these impairments did not meet or medically equal a listed impairment. The judge then determined that Samantha T. had the residual functional capacity—the most she could still do despite her impairments—to perform light work with certain modifications. Because she had no past relevant work, the judge considered other jobs and found that she could perform jobs existing in significant numbers in the national economy, including office helper, mail clerk, and wrapper counter. The judge concluded that she was not disabled from April 30, 2017, through June 17, 2024.

Issues and Analysis

Samantha T.’s testimony

Samantha T. argued that the administrative law judge improperly discounted her testimony about the severity of her psychological symptoms. The court explained that, when the required conditions are met, an administrative law judge must provide specific, clear, and convincing reasons for rejecting testimony about symptoms.

The court held that the administrative law judge met that standard. The administrative law judge considered examinations showing abnormal mood, limited or avoidant eye contact, and compulsive behaviors, but also relied on other examinations in which Samantha T. generally presented normally. Those records described, among other things, well-groomed appearance, cooperation, normal speech and affect, linear thought processes, and mild or moderate symptoms. The administrative law judge also considered reports that symptoms had improved and one opinion that Samantha T.’s presentation was not consistent with her reported depression.

The administrative law judge also considered Samantha T.’s activities, including performing at open mics, helping with an online business, doing household chores, conducting daily online research, making art, playing piano, writing songs, playing video games, and maintaining some social relationships. The court found that these activities were at least somewhat in tension with her testimony about her limitations and required varying degrees of sustained attention and concentration. Although the record also contained contrary evidence, the court held that it could not disturb the administrative law judge’s reasonable interpretation of the evidence.

Medical-opinion evidence

Samantha T. argued that the administrative law judge improperly evaluated Dr. Pedgrift’s opinion and failed to evaluate opinions from Dr. Marcaletti and therapist Ms. Potter. The court held that the administrative law judge adequately explained how persuasive Dr. Pedgrift’s opinion was and addressed its supportability and consistency with the record. The administrative law judge cited the opinion’s generalized and check-the-box format, inconsistencies concerning eye contact, observations suggesting stronger functioning than Dr. Pedgrift assessed, and inconsistency with other medical experts’ opinions that the administrative law judge found persuasive.

The court also held that the administrative law judge was not required to evaluate the opinions from Dr. Marcaletti and Ms. Potter as medical opinions under the applicable regulation. Although they discussed Samantha T.’s limitations, neither stated what she could still do despite her impairments. The court therefore rejected this challenge.

Listed impairments

Samantha T. argued that the administrative law judge erred at step three of the disability analysis by finding that her mental impairments did not meet or medically equal listed impairments 12.04, 12.06, or 12.10. The relevant mental-impairment criteria required at least one extreme limitation or two marked limitations in the areas of understanding and applying information, interacting with others, concentrating or maintaining pace, and adapting or managing oneself.

The court held that substantial evidence supported the administrative law judge’s finding that Samantha T. had only mild or moderate limitations in those areas. The evidence included her daily research, completion of her function report, high intelligence-test scores, intact cognition and memory, understandable communication, some interaction with friends and her boyfriend, adequate attention in some evaluations, and ability to live independently, prepare simple meals, and perform household chores.

Disposition

Judge Fitts concluded that the administrative law judge’s reasoning was clear, specific, and supported by substantial evidence. The court affirmed the Commissioner’s decision.