Young v. Berryhill

Background

Mary Ann Young applied for Social Security Disability Insurance benefits. The agency denied her application, and an Administrative Law Judge later found that she was not disabled. The Administrative Law Judge found severe impairments including a history of stroke, migraine headaches, and a gastrointestinal disorder following surgeries. He determined that Young could perform a limited range of light work, including work allowing her to sit or stand at will, and concluded that she could perform her past work as a resident supervisor. The Social Security Administration’s Appeals Council declined to review that decision, making it the agency’s final decision.

Young then sought review in federal court. She challenged only the Administrative Law Judge’s evaluation of her reports about the severity and effects of her migraine headaches. She testified that she typically had headaches almost every day, including severe headaches six to eight times per month. She said the headaches caused symptoms including disorientation, vision problems, nausea, vomiting, sensitivity to light and sound, sleep loss, and difficulty concentrating. A vocational expert testified that a person who missed even one day of work per month or was off task 10 percent of the time might not be employable in Young’s past work.

Court’s analysis

When a claimant provides medical evidence of an impairment that could cause the reported symptoms, and the Administrative Law Judge does not find that the claimant is exaggerating, the judge must give clear and convincing reasons for rejecting the claimant’s testimony about symptom severity. The judge may not reject that testimony solely because the medical evidence does not fully confirm its severity.

The court found that the Administrative Law Judge did not meet that standard. The Administrative Law Judge relied on Young’s ability to drive short distances, care for herself, do light household chores, prepare simple meals, shop, and handle money. He also summarized portions of the medical record, including a June 2013 note stating that Young could function with a headache on most days and a February 2015 report of four severe headaches in two months.

The court concluded that this discussion mischaracterized important evidence. The June 2013 record also stated that some headaches were incapacitating. The February 2015 record referred to four severe headaches, not four total headaches, and stated that the headaches could continue for several days after four hours of severe pain. The record also stated that migraine pain had awakened Young almost every night for several weeks. In addition, the Administrative Law Judge did not address September 2015 and May 2016 records in which Young reported daily or almost daily severe headaches and sought emergency treatment for a severe headache shortly before her hearing.

Outcome

The court held that the Administrative Law Judge had not provided clear and convincing reasons for discounting Young’s testimony. It therefore granted Young’s motion for summary judgment, denied the Commissioner’s cross-motion for summary judgment, and remanded the case for further proceedings consistent with the order. The order did not itself award benefits or state that Young was disabled.