Ramona R. v. Commissioner of Social Security

Background

Ramona R. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision on her disability-benefits claims. The parties filed cross-motions for summary judgment, asking the court to rule based on the administrative record.

Ramona R. alleged disability beginning July 4, 2014. The administrative law judge found that she had severe impairments including kidney disease, alcoholism, hepatitis C, and depression. Beginning February 13, 2017, the administrative law judge also found chronic liver disease and encephalopathy. The administrative law judge determined that Ramona R. could perform light work before February 13, 2017, with physical, environmental, and mental restrictions, and sedentary work beginning on that date with similar restrictions.

The administrative law judge found Ramona R. not disabled for disability insurance benefits through June 30, 2016, the date the administrative law judge identified as the date last insured. For supplemental security income, the administrative law judge found her disabled beginning February 13, 2017, but not before that date. The Appeals Council declined review, making the decision final.

Arguments and Evidence

Ramona R. argued that the administrative law judge failed to properly evaluate her mental impairment, particularly the opinion of consulting psychologist J. Larson, Psy.D. Dr. Larson diagnosed major depressive disorder with recurrent, severe depression and described marked limitations in several areas, including interacting with coworkers and the public, maintaining regular attendance, performing work consistently, and handling workplace stress.

The administrative law judge gave only partial weight to Dr. Larson’s opinion. The court explained that the administrative law judge relied on the one-time nature of the examination, Dr. Larson’s statement that additional information was needed to assess Ramona R.’s overall functioning, the absence of ongoing mental-health treatment or medication in more recent records, Ramona R.’s ability to answer questions and recall her medical and work history, and the opinions of state-agency psychological consultants who found only moderate limitations.

Ramona R. also argued that the administrative law judge did not adequately explain the change from light-work capacity before February 13, 2017 to sedentary-work capacity afterward. The court concluded that the administrative law judge reasonably relied on evidence of worsening liver disease, ascites requiring drainage, portal venous hypertension, hospitalization for weakness and functional decline related to chronic liver failure, altered mental status, and later encephalopathy.

Finally, Ramona R. challenged the administrative law judge’s treatment of Dr. N. Licht’s opinions. Dr. Licht stated in 2015 that Ramona R. was unemployable because alcoholism had caused cirrhosis, while a 2017 opinion attributed her inability to work to liver failure with cirrhosis, ascites, and encephalopathy. The court explained that whether a claimant is disabled is an administrative decision reserved to the Commissioner, but found that the administrative law judge’s treatment of the medical portions of Dr. Licht’s opinions was consistent with the record.

Ruling

The court held that substantial evidence supported the administrative law judge’s findings regarding Ramona R.’s mental impairment. It also held that the administrative law judge sufficiently explained the different residual functional capacity findings before and after February 13, 2017 and that the evidence supported the established onset date.

The court therefore DENIED Plaintiff’s motion for summary judgment and GRANTED Defendant’s cross-motion for summary judgment. The court directed the entry of a separate judgment and stated that the Clerk of Court would then terminate the case. Judge Thomas S. Hixson signed the order.