M.E.A. v. Bisignano

Background

M.E.A., who represented himself, sought judicial review of the Commissioner of Social Security’s denial of his application for disability insurance benefits under Title II of the Social Security Act. He alleged that migraine headaches, which he said began around 2003 and worsened in 2020, prevented him from working beginning January 15, 2022.

The administrative law judge found that M.E.A. had severe impairments consisting of migraines with mild hearing loss and tinnitus, and obesity. The judge found that he had the capacity to perform work at all exertional levels with limits involving ladders, noise, dangerous machinery, unprotected heights, and bright lights. The judge concluded that M.E.A. could perform his past relevant work as a post office supervisor and was not disabled. The Appeals Council declined to review that decision.

Court’s analysis

The court reviewed whether the Commissioner’s decision was supported by substantial evidence—meaning relevant evidence that a reasonable person could accept as adequate—and whether the correct legal standards were used.

The court held that the administrative law judge did not properly evaluate the consistency between M.E.A.’s reported migraine symptoms and the evidence in the record. The court identified several problems:

- The judge relied on an agency consultant’s isolated reference to “daily” migraines, even though the record generally showed that M.E.A. reported migraines several times per week. The court found no evidence corroborating a claim of daily migraines. - The judge improperly treated reports that medication made the migraines less intense as inconsistent with M.E.A.’s reports about how often the migraines occurred. The court explained that reduced intensity does not necessarily mean the migraines became nondisabling. - The judge characterized M.E.A.’s treatment as conservative without identifying evidence that alternative treatments were appropriate or available. The record also included M.E.A.’s testimony that clinicians had not discussed those alternatives with him. - The judge relied on a treatment gap, a declined neurology referral, and the lack of observed migraine symptoms without adequately addressing M.E.A.’s explanation that a prior neurosurgeon had told him nothing could be done. The court also found that the absence of observed symptoms did not necessarily conflict with migraine attacks that occurred outside medical examinations. - The judge relied on an apparent failure to take the prescribed dose of propranolol without asking M.E.A. why he had apparently taken less than the prescribed amount for some period. - The judge treated M.E.A.’s ability to perform basic activities when he was not having a migraine as inconsistent with his claim that he could not perform those activities during a migraine, without explaining the alleged conflict.

Because the administrative law judge did not provide specific, clear, and convincing reasons supported by substantial evidence for discounting M.E.A.’s symptom testimony and statements, the court concluded that remand was required.

Medical opinions and administrative findings

The administrative law judge found a work note from Dr. Addams not persuasive. The court agreed that the opinion’s statement that M.E.A. was unable to work addressed an issue reserved to the Commissioner, and that Dr. Addams did not cite objective findings supporting the stated functional limitations. But the court found error in the judge’s additional reliance on benign examinations, the absence of observed discomfort, conservative treatment, and the failure to follow up with a specialist, because those explanations were not supported by substantial evidence for the reasons discussed elsewhere in the opinion.

The agency consultants had recommended avoiding even moderate exposure to noise, vibration, and loud machinery, and one consultant also recommended avoiding bright lights. The court held that the administrative law judge did not sufficiently explain the rejection of the noise restriction. In particular, the judge appeared to focus on hearing results even though the relevant issue for migraines was whether noise triggered or worsened symptoms. The court found no error in the interpretation of the bright-lights restriction, under which normal indoor lighting was allowed while brighter lighting, such as direct sunlight or laboratory lighting, was excluded.

Other issues

The court found no error in the administrative law judge’s failure to analyze the Department of Veterans Affairs’ 50-percent disability rating because the applicable regulations do not require analysis of another agency’s decision about disability or entitlement to benefits.

The court also held that the vocational expert’s testimony about the amount of off-task behavior and absences employers would tolerate depended in part on the flawed evaluation of M.E.A.’s symptoms. That issue therefore required reconsideration on remand.

M.E.A. separately sought a remand based on a June 24, 2025 treatment note issued after the administrative law judge’s decision. The court concluded that he had not shown that the new information was material or that there was good cause for not presenting it earlier. The court therefore found no basis for that separate type of remand.

Disposition

The court reversed the Commissioner’s decision and remanded the case for further administrative proceedings. The court stated that it did not intend to limit the scope of the remand, directed entry of judgment, and ordered the file closed.