Nicholas C. v. Bisignano

Background

Nicholas C. sought judicial review of the denial of his applications for Social Security Disability Insurance and Supplemental Security Income benefits. He alleged disability beginning November 25, 2021, based on several mental-health conditions and other impairments. The Administrative Law Judge (ALJ) found severe impairments including bipolar disorder, major depressive disorder, generalized anxiety disorder, and attention deficit hyperactivity disorder. The ALJ determined that Nicholas C. did not meet or equal a listed impairment, had the capacity to perform work with specified nonphysical limitations, and could perform jobs available in the national economy. The Appeals Council denied review.

Structured Setting and Listed Impairments

Nicholas C. argued that the ALJ failed to address the effect of a structured setting when deciding whether his mental impairments met the requirements of the applicable listings. The court explained that the relevant paragraph C criteria require, among other things, ongoing reliance on treatment, mental-health therapy, psychosocial support, or a highly structured setting, along with only marginal adjustment.

The court concluded that the ALJ met the required minimum explanation. A medical expert testified that Nicholas C. did not satisfy the paragraph C criteria and that the record did not show reliance on a controlled environment. The ALJ found that opinion persuasive. The ALJ also cited evidence that Nicholas C. had stable housing, support from friends and family, no recent mental-health decompensation or manic episode, the ability to work part time, the ability to manage daily affairs and medications, and improvement with treatment. The court held that the ALJ’s reasoning was apparent from the decision as a whole and that further explanation was not required.

Residual Functional Capacity

Nicholas C. also argued that the ALJ’s residual functional capacity determination should have included the support he received from Guild, Inc., a mental-health case-management provider. The court rejected that argument. It relied on evidence that Nicholas C. could manage his own medications, transportation, and finances; was minimally engaged with the Guild team; and later discontinued Guild’s services while planning to receive monthly injections from another provider. The court concluded that substantial evidence supported the ALJ’s decision not to include the structured support setting in the residual functional capacity assessment.

Anticipated Absences

Nicholas C. argued that frequent medical and mental-health appointments, as well as missed appointments, would cause workplace absences that should have been included in the residual functional capacity assessment. The court found that he did not show that the appointments necessarily conflicted with a work schedule or required full-day absences. The court noted that many of the appointments involved Guild services that he discontinued, and that he often did not attend those appointments. The remaining appointments, including monthly injections, were not shown to be unusually frequent or disruptive. The court also found no clear connection between missed appointments and a likely pattern of workplace absenteeism.

Recommendation and Notice

The report recommends that Nicholas C.’s request to reverse or remand the Commissioner’s decision be denied and that the Commissioner’s request to affirm the decision be granted. The document states that it is a report and recommendation rather than an order or judgment and is not directly appealable to the Court of Appeals. The parties could file specific written objections within 14 days after being served with the report and recommendation.