Martin B.M. v. Commissioner of Social Security

Background

Martin B.M. applied for Disability Insurance Benefits and Supplemental Security Income Benefits in September 2021, alleging that he became unable to work on March 1, 2020. The Commissioner denied the applications. After an initial administrative hearing, the Social Security Appeals Council sent the matter back for further proceedings. Following a second hearing, Administrative Law Judge Seth Grossman again denied the applications on September 10, 2024. The Appeals Council denied further review on July 9, 2025, making the Administrative Law Judge’s decision the Commissioner’s final decision.

The Administrative Law Judge found that Martin B.M. had severe degenerative disc disease but did not have an impairment meeting or equaling one of the listed impairments in the regulations. The judge found that Martin B.M. could perform light work with limits, including standing or walking for four hours during an eight-hour workday and alternating sitting with standing or walking at specified intervals. Because he had no past relevant work but could perform jobs existing in significant numbers in the national economy, the Administrative Law Judge found that he was not disabled during the relevant period.

Issues and Analysis

Martin B.M. raised three main arguments: that the Administrative Law Judge improperly evaluated the severity of his right-wrist impairment; that the evaluation of the medical opinions undermined the finding about his remaining work abilities; and that the Administrative Law Judge improperly discounted his statements about pain and limitations.

On the wrist issue, the court acknowledged that the Administrative Law Judge did not provide an extensive analysis. The court nevertheless found no reversible error because the decision recognized the wrist condition and related complaints, the medical evidence supported treating it as non-severe, and the Administrative Law Judge stated that all medically determinable impairments—including non-severe impairments—were considered when determining the remaining work abilities.

Regarding the medical opinions, the court explained that the Administrative Law Judge had found the opinions of Dr. Silvia Aguiar, Dr. J. Sharif-Najafi, and Dr. Ronald Koenig generally persuasive. The court held that the Administrative Law Judge was not required to match the remaining-work-ability finding perfectly to any one medical opinion. It found that the additional restrictions included in the decision reasonably accounted for Martin B.M.’s reported pain and were supported by substantial evidence, meaning evidence that a reasonable person could accept as adequate.

The court also upheld the treatment of Martin B.M.’s subjective complaints. The Administrative Law Judge accepted that his impairments could cause the alleged symptoms but found that the claimed intensity and limiting effects were not entirely consistent with the record. The court concluded that the Administrative Law Judge reasonably considered treatment notes, imaging, clinical assessments, medical opinions, and daily activities.

Ruling

Judge Gary R. Jones held that the Commissioner’s decision was supported by substantial evidence and consistent with applicable law. The court denied Martin B.M.’s Motion for Judgment on the Pleadings, dismissed the case, directed the Clerk to enter final judgment in favor of the Commissioner, and directed that the file be closed.