Aaron v. Berryhill

Background

Anthony Aaron sought judicial review of the Commissioner of Social Security’s decision denying his applications for disability insurance benefits and Supplemental Security Income benefits. Aaron alleged disability based on paranoid schizophrenia. The administrative law judge found that Aaron was not disabled.

For the disability insurance claim, the administrative law judge found that Aaron’s date last insured was June 30, 2004 and concluded that he had no severe impairment as of that date. For the Supplemental Security Income claim, the administrative law judge found depression, anxiety, and polysubstance dependence in uncertain remission to be severe impairments, but rejected schizophrenia as an independently diagnosed impairment. He found that Aaron’s impairments did not meet or equal a listed impairment and determined that Aaron could perform work at all exertional levels, subject to limits to non-public, simple, repetitive tasks. At the final step, he relied on the Medical-Vocational Guidelines, commonly called the “Grids,” rather than obtaining testimony from a vocational expert.

Issues and Analysis

The court held that the administrative law judge improperly evaluated the medical evidence. Several prison psychiatrists diagnosed Aaron with schizophrenia, paranoid schizophrenia, or a psychotic disorder, and treatment records documented auditory hallucinations, paranoia, and medication for psychosis. The court found that the administrative law judge improperly dismissed this evidence as based on Aaron’s self-reports. In mental-health evaluations, the court explained, clinical interviews and mental-status observations are objective medical evidence.

The court also found that the administrative law judge did not give legally adequate reasons for rejecting treating psychologist Erica Conners’s opinions. The administrative law judge relied on the absence of a diagnosis in Conners’s weekly progress-note template and on Aaron’s attendance at community college. The court found that the template did not provide a place to list a diagnosis and that the administrative law judge did not address the accommodations Aaron received at college. The progress notes also described symptoms such as hallucinations, distractibility, anxiety, social difficulties, emotional instability, and declining functioning during stress.

The court found that the administrative law judge did not explain why he rejected or failed to address treating psychologist Gregory Girtman’s diagnosis of schizoaffective disorder and observations of Aaron’s hallucinations, paranoia, poor attention, difficulty following instructions, and difficulty getting along with others. The court also found that the administrative law judge gave no valid reason for assigning little weight to the state-agency psychologists’ opinions that schizophrenia was a severe impairment.

Because the administrative law judge rejected schizophrenia at the second step, he did not proceed beyond that step for the disability insurance claim. For the Supplemental Security Income claim, he failed to include in the residual functional capacity assessment many limitations associated with Aaron’s symptoms. The court concluded that this error prejudiced Aaron.

The court separately held that the administrative law judge’s reliance on the Grids was not supported by substantial evidence. The Grids may be used alone only when they fully describe a claimant’s abilities and limitations. Because the administrative law judge’s residual functional capacity assessment included non-exertional limitations, the court found that vocational-expert testimony was needed. Additional limitations associated with schizophrenia would also make reliance on the Grids inappropriate.

Disposition

The court granted Aaron’s motion for summary judgment and denied the Commissioner’s motion for summary judgment. It reversed the Commissioner’s decision and remanded the case to the Social Security Administration for further proceedings. The court determined that unresolved questions remained about Aaron’s limitations and ability to work, particularly because no vocational expert had testified. It did not order an immediate award of benefits.