Williamson v. Saul

Background

Earnie Williamson sought disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. He alleged disability beginning June 2, 2014, based on physical and mental conditions including post-traumatic stress disorder, gout, arthritis, poor circulation, chronic back and knee pain, and hearing loss.

An administrative law judge held a hearing and found Williamson not disabled. The administrative law judge determined that Williamson’s only severe impairment was a left-knee fracture and that he did not have an impairment, or combination of impairments, that met or medically equaled a listed impairment. The judge found that Williamson had the residual functional capacity—the most he could still do despite his impairments—to perform a full range of medium work with certain limitations. The judge concluded that Williamson could perform his past work as a janitor and other jobs existing in significant numbers in the national economy. The Social Security Administration’s Appeals Council denied review, making the administrative law judge’s decision the Commissioner’s final decision.

Issues and Analysis

Williamson challenged the decision on three grounds: whether the administrative law judge improperly found only one severe impairment; whether the judge improperly weighed the medical opinions; and whether the judge incorrectly formulated Williamson’s residual functional capacity and applied Social Security Grid Rule 202.04.

The court held that substantial evidence supported the finding that Williamson’s left-knee impairment was severe. It rejected Williamson’s arguments concerning his mental impairments because he did not identify evidence showing that post-traumatic stress disorder or major depressive syndrome was severe, and he did not specifically challenge the administrative law judge’s findings. The court also found that any failure to separately identify left-knee degenerative joint disease at the second step of the disability analysis was harmless because the administrative law judge discussed the knee evidence later in the decision.

The court further concluded that Williamson had not shown that his lumbar spine condition or cervical spondylosis caused functional limitations requiring a finding of additional severe impairments. The medical records cited by the court included generally normal findings and did not establish significant work-related effects from those conditions. The court therefore found that any error in considering the additional impairments was harmless because the administrative law judge considered the relevant medical evidence elsewhere in the decision.

The court upheld the administrative law judge’s treatment of the medical opinions. Because Williamson’s claim was filed before March 27, 2017, the court explained that Nurse Practitioner Lewis Simpler was not an acceptable medical source under the applicable rules and was entitled to less deference. The administrative law judge gave Simpler’s opinion little weight because it was overly restrictive and inconsistent with the overall medical evidence. The court found those to be adequate reasons under the applicable standard.

The court also upheld the great weight given to the opinions of consultative examiner Dr. McMillan and non-examining state-agency consultants Drs. Jones and Sohn. The administrative law judge found those opinions consistent with the record and supported by examination findings. The court concluded that the reasons for relying on those opinions were supported by substantial evidence.

Finally, the court held that substantial evidence supported the residual functional capacity finding because Williamson’s challenge to that finding depended on his rejected arguments about the medical evidence.

Disposition

The court denied Williamson’s motion for summary judgment, granted the Commissioner’s cross-motion for summary judgment, and affirmed the Commissioner’s decision denying benefits. Judge Jacquelyn Corley issued the order on January 16, 2020.