Karakoc v. Berryhill

Background

Cengiz Karakoc sought judicial review of an administrative law judge’s decision denying his application for Title II disability insurance benefits. He alleged disability beginning April 7, 2011, and his last-insured date was December 31, 2015. The administrative law judge denied the application, and the Social Security Appeals Council declined review.

The administrative law judge found severe impairments involving Karakoc’s left shoulder, spine, right wrist, elbow, knees, and obesity. The judge found that depression and anxiety were not severe because they caused no more than minimal limitations in basic mental work activities. The judge determined that Karakoc could perform light work with limitations, could not perform his past relevant work, but could perform jobs available in the national economy.

Karakoc challenged the findings that his depression and anxiety were non-severe, that the administrative law judge failed to consider all of his impairments together when determining his residual functional capacity, and that the judge improperly evaluated his credibility. The opinion states that Karakoc received weekly mental-health treatment from Claudette de Carbonel, Ph.D., MFT, from 2016 through 2017. The record also included treatment evidence from Dr. Kulthia and other providers concerning anxiety and depression.

Court’s analysis

The court explained that the second step of the disability process is a minimal screening stage for eliminating groundless claims. It found significant evidence of depression and anxiety from late 2015 through 2017. The administrative law judge relied on a 2015 consulting examination and opinions from state agency reviewers, but those opinions came before, and therefore did not consider, the later treatment and records from Dr. de Carbonel and Dr. Kulthia.

The court held that it was unreasonable to reject Dr. de Carbonel’s opinion in favor of the earlier opinions from non-examining reviewers and the consulting examiner. The court also held that the administrative law judge failed to discuss Dr. Kulthia’s treatment of Karakoc’s anxiety, even though those records were contemporaneous with and supported Dr. de Carbonel’s treatment and opinions. According to the court, this failure did not satisfy the obligation to address significant evidence supporting Karakoc’s claimed limitations. The court stated that, if the administrative law judge had questions about the treating providers’ opinions, the judge should at least have obtained a later state-agency review of the treatment records.

Disposition

The court granted Cengiz Karakoc’s motion for summary judgment and denied Andrew Saul’s motion for summary judgment. It remanded the case for further proceedings consistent with the order. The court declined to decide Karakoc’s remaining arguments because the disability analysis could change after the error concerning his mental impairments was corrected.