Joselyn M. v. Commissioner of Social Security

Background

Joselyn M. applied for Disability Insurance Benefits in September 2021, alleging that she became unable to work on June 1, 2018. The Social Security Administration denied the application initially and again on reconsideration. After two hearings, an administrative law judge (ALJ) denied benefits on January 23, 2024. The Appeals Council declined review on September 13, 2024, making the ALJ’s decision the Commissioner’s final decision.

The ALJ found that Joselyn M. had several severe impairments, including right wrist tendon inflammation, spinal conditions, headaches with vertigo and hearing loss, generalized anxiety disorder, and bipolar depressive disorder. The ALJ determined that she could perform a reduced range of light work. The restrictions included limits on lifting, standing, walking, reaching, handling, exposure to noise and hazards, and certain physical movements. The ALJ also limited her to low-stress jobs, allowed one unscheduled absence every 60 days, and allowed her to be off task for up to 5% of the workday beyond regular breaks. Although she could not return to her past work as a babysitter, the ALJ found that other jobs existed in significant numbers that she could perform.

Joselyn M. filed this federal case seeking review of that decision. She moved for judgment on the pleadings, which asks the court to decide the case based on the existing court record without a trial. She argued that the ALJ improperly evaluated the medical-opinion evidence and improperly discounted her reports of pain and other limitations.

Medical-opinion evidence

The court applied the substantial-evidence standard. Under that standard, the court does not decide disability anew; it asks whether relevant evidence supports the Commissioner’s decision and whether the correct legal standards were used.

For physical functioning, the court upheld the ALJ’s evaluation of Dr. Rami Ravi’s opinion. Dr. Ravi found moderate limitations in standing, walking, bending, reaching overhead, pushing, pulling, lifting, and carrying. The court concluded that moderate limitations could be consistent with a reduced range of light work. It also found support in examination and treatment records showing, among other things, full strength, generally normal gait, and generally full range of motion, as well as in the opinions of two state-agency reviewing physicians. The court noted that the ALJ included additional physical restrictions in the residual functional capacity assessment rather than simply adopting the less restrictive state-agency opinions.

For mental functioning, the ALJ found no limitation in understanding, remembering, or applying information and interacting with others, but moderate limitations in concentration, persistence, or pace and in adapting or managing oneself. The court acknowledged that the ALJ’s discussion of the mental-health opinions was not clear about precisely which portions of the opinions were rejected. It nevertheless found the error harmless because the ALJ’s reasoning could be understood from the decision as a whole and the mental restrictions were supported by substantial evidence. The court pointed to the opinions of Dr. Todd Deneen and Craig Lavin, treatment records, mental-status examinations, and the ALJ’s restrictions to low-stress work with limited absences and off-task time.

Subjective complaints

Joselyn M. testified about severe wrist, back, and neck pain, migraines, vertigo, mental-health symptoms, difficulty sitting, standing, walking, and lifting, and the need to lie down during the day. The ALJ found that her medical impairments could reasonably produce her symptoms but that her statements about their intensity and limiting effects were not fully consistent with the record.

The court upheld that assessment. It found that the ALJ reasonably considered the treatment records, medical opinions, and daily activities, including some work activity and childcare. The court concluded that the ALJ gave specific record-based reasons for finding that the evidence supported a reduced range of light work rather than total disability.

Disposition

The court denied Joselyn M.’s Motion for Judgment on the Pleadings and dismissed the case. It directed the clerk to enter final judgment in favor of the Commissioner and close the file.