Nathan L. v. Frank Bisignano, Commissioner of Social Security Administration

Background

Nathan L. applied for supplemental security income in May 2021 because of a disability. After the application and reconsideration request were denied, Nathan received a hearing before an administrative law judge (ALJ). Psychological experts said he could manage “brief and superficial” interactions with coworkers, supervisors, and the public. The first ALJ instead described his residual functional capacity (RFC)—his ability to perform sustained work despite health limitations—as allowing occasional interaction with supervisors, coworkers, and the public, and found that he could perform medium work.

Nathan challenged that decision. In an earlier round of this case, the court remanded for further proceedings because it could not determine whether the ALJ had omitted, improperly combined, or failed to explain the experts’ recommended social-interaction limitation.

On remand, a new ALJ again found that Nathan was not disabled and was not eligible for supplemental security income. The new RFC stated that Nathan could understand, remember, and carry out simple instructions; make simple work-related decisions; occasionally interact with supervisors and coworkers; and have no interaction with the public. The ALJ explained that “brief and superficial” was vague and undefined and that she used more specific, vocationally defined language instead. She also stated that the RFC addressed the frequency and type of Nathan’s social interactions.

Nathan’s Objections

Nathan objected to the recommendation that the court affirm the ALJ’s decision. He argued that the ALJ did not adequately incorporate the experts’ opinions, that instructions and interactions have different meanings, and that “occasional” describes frequency while “superficial” describes the quality of an interaction.

Court’s Analysis

The court reviewed the challenged portions of the magistrate judge’s report and recommendation independently. It explained that the Commissioner’s findings must be upheld if supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate to support the conclusion.

The court held that the ALJ was not required to use the experts’ exact words. The ALJ explained why she used different terminology and identified specific limits on the frequency and nature of Nathan’s workplace interactions. The court therefore found no error in the ALJ’s wording or explanation.

The court also rejected Nathan’s argument that the ALJ ignored the experts’ recommendation about superficial interactions. It concluded that the ALJ addressed the quality of social interactions through the limitations involving simple instructions and decisions, together with the restrictions on interaction with supervisors, coworkers, and the public. The court stated that the ALJ’s decision was supported by substantial evidence.

Disposition

The court adopted the report and recommendation, overruled Nathan L.’s objections, denied Nathan L.’s request for relief, granted the Commissioner’s request for relief, and affirmed the Commissioner’s decision. The complaint was dismissed with prejudice, meaning the court’s order barred refiling that complaint. The opinion states that judgment was to be entered accordingly.