A.K. v. Commissioner

Background

A.K. sought judicial review of the Commissioner’s final decision denying her application for Title II disability insurance benefits. She alleged a disability onset date of January 4, 2017, based on physical and mental conditions, including knee and back problems, bipolar disorder, anxiety, post-traumatic stress disorder, and autism. The court stated that A.K. had exhausted her administrative remedies and that it had authority to review the decision under 42 U.S.C. § 405(g).

A first administrative law judge denied benefits in July 2022. The Appeals Council vacated that decision and sent the matter back for further proceedings because the decision did not adequately address mental limitations in the work-capacity assessment or explain why certain medical opinions about mental limitations were not adopted. On remand, a different administrative law judge again denied benefits in May 2024.

The second administrative law judge found that A.K. had severe physical and mental impairments but did not have an impairment, or combination of impairments, meeting the regulatory listings. The judge found that A.K. could perform light work with physical restrictions and could do simple work, have occasional interaction with others, and experience occasional changes in a routine work setting. Although A.K. could not perform her past relevant work, the judge found at the final step that jobs existed in significant numbers in the national economy that she could perform.

Standard of Review

The court could disturb the Commissioner’s decision only if the administrative law judge committed legal error or made findings unsupported by substantial evidence. The court defined substantial evidence as relevant evidence that a reasonable person might accept as adequate to support a conclusion. When the evidence supports more than one reasonable interpretation, the court must uphold the administrative law judge’s interpretation.

Mental-Health Medical Opinions

A.K. argued that the administrative law judge improperly evaluated the opinion of Terri Vazquez, a medical source who provided a statement about A.K.’s mental limitations. Vazquez described several symptoms and opined that A.K. had moderate limitations in daily activities, social functioning, and concentration, persistence, or pace. She also identified possible episodes of decompensation and opined that A.K. might miss two workdays per month because of psychological symptoms.

The administrative law judge found Vazquez’s opinion partially persuasive. The court upheld that assessment. It explained that the opinion was not supported by specific clinical findings or treatment notes and that the record did not clearly show Vazquez had directly treated A.K. The court also found that the opinion was inconsistent with other evidence, including examinations and treatment records describing generally intact memory, concentration, judgment, cognition, and thought processes. The court noted that the administrative law judge had included meaningful mental restrictions rather than finding that A.K. had no mental limitations.

The court also addressed evidence of a serious mental-health episode in 2019 and a 2020 therapist note describing manic and depressive symptoms. It found that this evidence did not establish error because other treatment records described A.K.’s bipolar disorder as in remission and did not support disability based on anxiety or insomnia. The court concluded that the administrative law judge did not err in evaluating Vazquez’s opinion.

Physical Medical Opinions

A.K. also challenged the treatment of opinions from J. Allen, a state-agency medical consultant, and Justin Ebert, a physician assistant who provided a treating-source statement. Allen opined that A.K. could lift or carry certain weights and stand, walk, and sit for about six hours in an eight-hour workday. Ebert offered more restrictive limitations, including lifting less than 10 pounds, standing or walking less than two hours, and sitting less than six hours. Ebert also stated that A.K. used a walker that improved her stability and was medically necessary.

The administrative law judge found Allen’s opinions partially persuasive and Ebert’s opinions unpersuasive. The court upheld those assessments. It agreed that Ebert’s statement lacked supporting medical findings and relied on reports of pain. The court also found that the medical records were inconsistent about A.K.’s use of a cane or walker. Some records described use of an assistive device and slow or guarded movement, while others described normal gait, normal strength, or walking without an assistive device. The court further noted that imaging generally showed only mild degenerative changes, and that one provider who prescribed a walker did not otherwise believe the condition qualified A.K. for disability.

Disposition

The court denied A.K.’s request for relief. It directed the clerk to enter final judgment in accordance with the decision and close the file. The order disposed of Docket Nos. 12-13.