Leroy S. v. Bisignano

Background

Leroy S. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying his application for Supplemental Security Income (SSI). He had originally applied for both disability insurance benefits (DIB) and SSI, alleging disability beginning January 1, 2019. At the administrative hearing, his lawyer amended the alleged onset date to October 25, 2022. The administrative law judge (ALJ) determined that this amendment eliminated the DIB claim and dismissed that claim on that basis. The court did not address the DIB claim further on the merits.

As to SSI, the ALJ found severe impairments including diabetes with diabetic foot ulcers and a history of bilateral digital amputations, peripheral neuropathy, and generalized anxiety disorder. The ALJ found that Leroy S. had the residual functional capacity (RFC)—the most he could still do despite his impairments—to perform light work with physical restrictions that he did not challenge. The ALJ also found that he could understand, remember, and carry out simple instructions; have occasional interaction with the public; have frequent but not constant interaction with supervisors and coworkers; and handle occasional changes in a routine work setting. Based on vocational-expert testimony, the ALJ found that at least 161,000 jobs existed nationally that he could perform and concluded that he was not disabled for SSI purposes.

Issue

Leroy S. challenged only the ALJ’s treatment of state-agency psychological consultants’ findings about workplace interaction. The consultants had found that he could interact only briefly and superficially with coworkers and supervisors and should have limited public contact. Leroy S. argued that the ALJ improperly increased those interaction limits and failed to adequately consider the limited social settings in which he had meaningful interactions.

Court’s analysis

The court reviewed whether the ALJ’s decision was supported by substantial evidence—the relevant evidence that a reasonable person could accept as adequate—and whether the decision contained legal error.

The court first held that the ALJ used the proper legal framework. Social Security regulations require an ALJ to evaluate the persuasiveness of medical opinions, especially their supportability and consistency. Supportability concerns how well an opinion is supported by objective medical evidence; consistency concerns how well it fits with other relevant medical and nonmedical evidence. The court explained that an ALJ may accept some, but not all, of a medical opinion when the reasoning is sound and supported. The ALJ need not mechanically cite Social Security Ruling 96-8p if the decision otherwise considers and explains the medical findings as required.

The court found that the ALJ explained why parts of the consultants’ opinions were unpersuasive. The ALJ considered the record’s evidence that Leroy S. had no more than moderate limitations interacting with others and that he had not reported problems getting along with people.

The court also held that substantial evidence supported the ALJ’s decision to allow somewhat more workplace interaction than the consultants recommended. The record showed that Leroy S. got along with family, friends, and others; had not been fired for interpersonal problems; lived with a roommate and in a sober house; spent leisure time with others; attended chemical-health meetings; and reported daily social activities. He also reported handling stress and routine changes well. The court stated that it could not reweigh the evidence or redo the ALJ’s evaluation merely because another conclusion might also have been reasonable.

Disposition

The court denied Leroy S.’s request for reversal, granted the Commissioner’s request for affirmance, and ordered judgment accordingly. The Commissioner’s denial of SSI therefore remained in place.