Todd L. v. Bisignano

Background

Todd L. appealed the administrative law judge’s decision finding him not disabled. He applied for supplemental security income on January 10, 2023, alleging disability beginning March 15, 2022. The administrative law judge held a hearing on April 17, 2024, and issued a decision on June 4, 2024.

The administrative law judge found that Todd had several severe impairments, including obesity, mixed anxiety and depressive disorder, attention deficit hyperactivity disorder, bipolar disorder, posttraumatic stress disorder, antisocial personality disorder, and a history of polysubstance use disorder. Todd had also experienced civil commitment from May 2022 through April 2023, although he received inpatient care from May 2022 through September 12, 2022.

Todd challenged the administrative law judge’s step-three finding and residual functional capacity assessment. Residual functional capacity means the work-related activities a person can still perform despite limitations from impairments.

Step-Three Analysis

At step three, a claimant must show that an impairment or combination of impairments meets or medically equals a listed impairment. Todd argued that the administrative law judge did not identify enough supporting evidence and did not properly consider the effects of structured settings under the paragraph C criteria for Listings 12.04 and 12.06.

The paragraph C criteria require a serious and persistent mental disorder, a documented history of at least two years, ongoing treatment or support that reduces symptoms, and marginal adjustment—meaning minimal ability to adapt to changes or demands outside the person’s daily life.

Judge Bullard concluded that substantial evidence supported the administrative law judge’s finding that Todd did not satisfy those criteria. The administrative law judge relied on evidence that, after discharge, Todd could live alone, perform household tasks, prepare simple food, shop, manage finances and health care, attend recovery meetings, and participate in outpatient treatment. The administrative law judge also considered evidence that Todd generally reported doing well, maintained sobriety, had normal mental-status findings, and received medication management and outpatient treatment.

Judge Bullard rejected Todd’s argument that the administrative law judge failed to consider his civil commitment and inpatient treatment. The recommendation stated that the administrative law judge acknowledged that history but reasonably focused on Todd’s more recent functioning after discharge. The recommendation also stated that the court could not reweigh the evidence when substantial evidence supported the administrative law judge’s conclusion.

Residual Functional Capacity

Todd argued that the residual functional capacity assessment failed to account for the support he needed to function. His specific challenge concerned Dr. Sathoff’s opinion that Todd had marked limitations in interacting with supervisors. Dr. Sathoff had previously described that limitation as moderate but later changed it to marked after Todd reported being fired from two jobs because of problems with supervisors.

The administrative law judge found Dr. Sathoff’s later opinion unpersuasive. The judge reasoned that Todd’s subjective reporting may have influenced the opinion, that the marked limitation was inconsistent with Dr. Sathoff’s treatment records showing normal mental-status findings, and that other records described Todd as displaying normal behavior and cooperation.

Judge Bullard concluded that the administrative law judge gave specific reasons supported by medical evidence for discounting the opinion. The recommendation also noted that Todd did not challenge the administrative law judge’s assessment of Dr. Sathoff’s objectivity or explain why the cited evidence was inadequate. Because substantial evidence supported the residual functional capacity assessment, the recommendation rejected Todd’s request for a remand.

Recommended Disposition

Judge Bullard recommended that Todd’s requested relief be denied and that the complaint be dismissed with prejudice. The document was a report and recommendation rather than a final district court order. It stated that the recommendation was not directly appealable to the U.S. Court of Appeals for the Eighth Circuit and that objections could be filed within 14 days after service.