Karin R. v. Bisignano

Background

Karin R. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s decision denying her disability insurance benefits and supplemental security income for the period from October 1, 2015, through November 15, 2021. The Commissioner had already found Karin R. disabled beginning November 15, 2021, and she was receiving benefits based on that finding.

This was the third appeal to the District of Minnesota. Earlier proceedings resulted in remands for further administrative consideration, including consideration of Karin R.’s mental impairments when determining her residual functional capacity. In the current proceeding, the issue was limited to whether the administrative law judge properly evaluated testimony from Michael Lace, Psy.D., about whether chronic pain could aggravate Karin R.’s mental-health impairments and cause excessive absenteeism.

At the May 16, 2025 hearing, Dr. Lace testified that chronic pain could sometimes worsen mental-health symptoms and interfere with concentration. When asked to quantify absenteeism, he said he could not really do so. In response to counsel’s question about whether one to three missed workdays per month would be possible, he said that it would be possible but that he could not go further.

The administrative law judge found that the testimony supported moderate mental-functioning limitations but found unpersuasive the portion suggesting that Karin R. could possibly miss up to three workdays per month. The administrative law judge determined that Karin R. could perform a restricted range of light work and could perform jobs such as merchandise marker, mail sorter, or collator operator. The administrative law judge therefore found that she was not disabled before November 15, 2021.

Court’s analysis

The court reviewed whether substantial evidence supported the administrative law judge’s decision and whether the decision resulted from an error of law. It held that the record did not clearly document a connection between Karin R.’s chronic pain, the specific mental-health impairments identified in the decision, and one to three monthly absences from work.

The court explained that Dr. Lace did not expressly state that Karin R. would miss one to three workdays per month. Instead, he described that level of absenteeism as possible after acknowledging that he could not quantify it and that the effects of chronic pain were unpredictable. The court also found that the treatment records cited by Karin R. did not provide the claimed connection or establish related absenteeism.

The court rejected Karin R.’s argument that the administrative law judge failed to address the required regulatory factors for evaluating medical opinions. Those factors include supportability—how well an opinion is supported by the source’s evidence and explanation—and consistency—how well it fits with other evidence in the record. The court found that the administrative law judge addressed those considerations by identifying the lack of medical evidence supporting absences of up to three days per month and by considering other evidence, including Karin R.’s daily activities and reported improvement from treatment and medication.

The court concluded that substantial evidence supported the administrative law judge’s evaluation of Dr. Lace’s testimony, the residual functional capacity finding, and the conclusion that Karin R. was not disabled during the disputed period.

Disposition

Judge Susan Richard Nelson denied the relief requested in Karin R.’s brief, granted the Commissioner’s brief requesting affirmance of the decision, and dismissed Karin R.’s complaint with prejudice. The court ordered that judgment be entered accordingly.