Transito G. v. Commissioner of Social Security

Background

Transito G. applied for Disability Insurance Benefits and Supplemental Security Income in April 2015, alleging disability beginning June 30, 2014. The Social Security Administration denied the applications. After several administrative hearings, two decisions by Administrative Law Judge Moises Penalver, an earlier federal court action, and a remand by agreement of the parties, Administrative Law Judge Lori Romeo issued another decision denying benefits on April 19, 2024. The Appeals Council denied review on July 14, 2025, making that decision the Commissioner’s final decision.

Judge Romeo found that Transito G. had several severe physical impairments, including degenerative disc disease in the cervical and lumbar spine and joint disease affecting her shoulders, left knee, and left ankle. She determined that Transito G. could perform sedentary work with several restrictions, including the ability to stoop occasionally. Because the administrative law judge found that jobs existed in significant numbers that Transito G. could perform, she concluded that Transito G. was not disabled. Transito G., represented by Francesca Zeltmann, moved for judgment on the pleadings. The Commissioner opposed the motion and requested judgment on the pleadings.

Court’s Analysis

The court reviews a Social Security decision to determine whether substantial evidence supports it and whether the Commissioner applied the correct legal standard. The court does not decide the disability question anew. When a claimant has a treating physician, the administrative law judge must evaluate that physician’s opinion under the applicable treating-physician rules, including the physician’s treatment relationship, supporting medical evidence, consistency with the record, and specialty.

Dr. Gerardo Miranda-Comas, a treating physician, stated in April 2018 that Transito G. should never stoop. Administrative Law Judge Romeo gave the opinion little weight, finding it unsupported by the treatment record and inconsistent with opinions from consultative examiners Dr. Ram Ravi and Dr. Eugene Edynak and medical expert Dr. Abdilahli Elmi.

The court found that the administrative law judge did not meaningfully explain the conclusion that Transito G. could stoop occasionally. It also found that the administrative law judge incorrectly treated the medical opinions as inconsistent on stooping. Dr. Ravi said Transito G. should avoid squatting, and Dr. Elmi testified that stooping and bending should be avoided. Thus, on the critical issue of stooping, those opinions supported rather than contradicted Dr. Miranda-Comas’s opinion.

The error was material. The court noted that a complete inability to stoop can significantly reduce the range of unskilled sedentary work. The vocational expert testified that a person with Transito G.’s residual functional capacity who could not stoop could not perform substantial gainful activity. The court rejected the Commissioner’s argument that the error was harmless and said the Commissioner’s briefing could not supply reasoning missing from the administrative law judge’s decision.

Disposition

The court held that the administrative law judge’s failure to properly address the medical opinion evidence about stooping materially undermined the residual-functional-capacity finding and that the decision denying benefits could not be sustained. Because the record was complete, contained persuasive proof of disabling physical limitations, and had already gone through multiple hearings and court proceedings over more than a decade, the court determined that another administrative proceeding was not appropriate.

The court GRANTED Transito G.’s motion for judgment on the pleadings, denied the Commissioner’s request, and remanded the case for calculation of benefits. The Clerk was directed to enter final judgment in favor of Transito G. and close the file.