Walton v. Berryhill

Background

Kimberly B. Walton challenged an administrative law judge’s decision denying her application for Supplemental Security Income under Title XVI of the Social Security Act. The parties filed cross-motions for summary judgment, a procedure in which the court decides whether the administrative decision can stand based on the record and applicable law.

The administrative law judge found that Walton had several severe impairments, including depression, posttraumatic stress disorder, hypertension, obesity, and degenerative disc disease. The record also contained evidence of sciatic nerve damage causing substantial pain in her left leg. The administrative law judge determined that Walton had not been disabled since she applied for benefits on November 3, 2014. The judge assigned Walton a residual functional capacity—the most she could still do despite her impairments—for a limited range of medium work, with restrictions on postural activities, climbing, and contact with coworkers and the public.

Court’s Analysis

The court applied the rule that a Social Security denial may be disturbed when it lacks substantial evidence or rests on a non-harmless legal error. The court found both legal error and reasons to question whether the decision was supported by substantial evidence.

The primary error concerned the opinion of Dr. Karen Mu, who provided Walton outpatient psychiatric services beginning in June 2015. Dr. Mu and Stefanie Breedy wrote that Walton would be unable to manage the routines, responsibilities, and social interactions required in a work setting for at least 12 months despite treatment and support. The administrative law judge did not state what weight was given to Dr. Mu’s opinion, saying only that it was not entitled to controlling weight.

The court concluded that the administrative law judge did not give the specific and legitimate reasons, supported by substantial evidence, required to reject or discount the treating provider’s opinion. The court found inadequate the judge’s reliance on notes indicating that medication had helped control Walton’s symptoms because other records reported suicidal ideation and difficulty performing daily activities. The court also explained that periods of improvement do not necessarily show that a person can work when the record reflects recurring debilitating symptoms.

The administrative law judge also relied on Walton’s reported daily activities, including caring for herself, watching television, shopping, handling finances, going outside, cooking, and cleaning. The court noted contrary evidence that Walton’s depression sometimes prevented her from leaving bed and explained that ordinary home activities do not necessarily transfer to the more demanding conditions of a workplace.

Finally, the court found that the administrative law judge improperly rejected portions of Dr. Mu’s and Ms. Breedy’s opinion on the ground that disability is an issue reserved to the Commissioner. The court stated that medical providers may offer opinions about a claimant’s ability to work. The court also identified apparent inconsistencies concerning whether Walton had been psychiatrically hospitalized and whether her treatment had been routine and conservative, given the record’s reference to a 2015 hospitalization for suicidal ideation and psychiatric emergency services.

Disposition

The court held that these errors were not harmless because it could not conclude that they had no effect on the decision denying benefits. The court declined to address Walton’s other arguments because the failure to properly evaluate Dr. Mu’s opinion alone required a remand.

Walton asked the court to direct an award of benefits under the credit-as-true rule, which can permit benefits when improperly rejected evidence is treated as established. The court denied that request because the record as a whole did not compel a finding of disability. Instead, the court granted Walton’s motion for summary judgment, denied the defendant’s motion, and remanded the case to the Social Security Administration for further proceedings consistent with the order.