Christopher D. M. v. Berryhill

Background

Christopher D. M. applied for disability insurance benefits and supplemental security income, alleging that he became disabled on June 13, 2013. After a hearing at which Christopher and a vocational expert testified, the administrative law judge (ALJ) denied benefits on November 2, 2016.

The ALJ found that Christopher had severe impairments including a mood disorder, bipolar disorder, sensory integration disorder, and Asperger’s syndrome. The ALJ determined that Christopher could perform work at all physical exertional levels, but limited him to simple, routine, and repetitive tasks; work without fast-paced production requirements; simple work-related decisions; few workplace changes; limited interaction with the public, coworkers, and supervisors; and limited noise exposure.

Christopher’s treating psychiatrist, William Sastry, described substantial problems with concentration, anxiety, sensory overload, social interactions, and maintaining school and work. Sastry opined that Christopher could not maintain meaningful employment and could not consistently sustain even part-time, low-level manual work. A consultative psychologist, Jonathan Howard, also identified impairments affecting Christopher’s concentration, social interactions, pace, persistence, attendance, and ability to adapt, although the ALJ gave Howard’s opinion greater weight.

Court’s Analysis

The court reviewed the Commissioner’s decision under 42 U.S.C. § 405(g), which permits a court to set aside the decision for legal error or for findings not supported by substantial evidence. Substantial evidence means relevant evidence that a reasonable person could accept as adequate support for a conclusion.

The court held that the ALJ failed to give specific and legitimate reasons for rejecting Sastry’s medical opinions about Christopher’s functional limitations. The ALJ had summarized Sastry’s view that Christopher was disabled and could not hold a job, but rejected the opinion on the ground that it exceeded Sastry’s expertise and concerned an issue reserved to the Commissioner.

The court found that this reasoning did not address Sastry’s detailed medical opinions about Christopher becoming overwhelmed in ordinary workplace settings, having trouble focusing on simple tasks, and being unable to maintain work. The court also found the error harmful because the vocational expert testified that a person unable to concentrate consistently for two-hour periods could not sustain gainful employment.

The court separately held that the ALJ failed to comply with Social Security Ruling 96-5p. Although the ultimate disability decision is reserved to the Commissioner, the ruling required the ALJ to consider medical-source opinions on that issue and evaluate whether the record supported them. If the basis for such an opinion was unclear, the ALJ was required to make reasonable efforts to contact the medical source for clarification. The court found that the ALJ did neither and instead rejected Sastry’s opinion solely because it concerned an issue reserved to the Commissioner.

Disposition

Judge Sallie Kim GRANTED Christopher’s motion for summary judgment and DENIED the Commissioner’s cross-motion for summary judgment. The court REMANDED the action for full consideration of Sastry’s opinions. The court further directed that, if the ALJ found the basis for Sastry’s opinion that Christopher was disabled unclear, the ALJ must make every effort to recontact Sastry for clarification.