Yacoobali v. Saul Acting Commissioner of Social Security

Background

Ismail Y. Yacoobali applied for disability insurance benefits under Title II of the Social Security Act. He alleged that he became unable to work on May 3, 2013, because of a neck and left shoulder injury, pain and weakness in his left upper extremity, hearing loss, headaches, depression, and anxiety. The Social Security Administration denied the application.

After a hearing, an Administrative Law Judge (ALJ) found that Yacoobali had severe impairments, including degenerative disc disease of the cervical spine, depression, and generalized anxiety disorder. The ALJ found that his impairments did not meet or equal a listed impairment. The ALJ determined that Yacoobali retained the residual functional capacity (RFC) to perform a reduced level of light work, with physical and mental restrictions. Although he could not perform his past relevant work, the ALJ found, based on vocational-expert testimony, that he could perform other jobs existing in significant numbers in the national economy. The ALJ therefore found him not disabled.

Yacoobali sought judicial review under 42 U.S.C. § 405(g). Both sides moved for summary judgment, asking the court to decide the case based on the administrative record.

Court’s Analysis

The court could overturn the Commissioner’s decision only if it was based on legal error or was not supported by substantial evidence. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support the decision.

Evaluation of Yacoobali’s testimony. The court upheld the ALJ’s conclusion that some of Yacoobali’s statements about the severity of his symptoms were inconsistent with the medical evidence and his reported activities. The ALJ considered examinations showing limited but not extreme strength deficits, imaging that did not show severe spinal narrowing, normal electromyography and nerve-conduction testing, generally normal or near-normal mental-status examinations, Yacoobali’s international travel, driving, academic performance, participation in religious services, and improvement with mental-health treatment. The court found that the ALJ gave specific reasons supported by the record for discounting parts of Yacoobali’s testimony.

Medical opinions. The ALJ assigned partial weight to the opinions of examining doctors Rose Lewis and Tania Shertock. The court found that the ALJ reasonably explained why parts of Dr. Lewis’s physical limitations were inconsistent with her examination findings and the rest of the record. The court also found that the ALJ reasonably translated Dr. Shertock’s mental limitations into restrictions to simple, repetitive work with occasional public contact and properly discounted portions of her opinion that were inconsistent with Yacoobali’s activities and examination findings.

Available work. Yacoobali argued that the ALJ had not properly addressed possible conflicts between the vocational expert’s testimony and the Department of Labor’s Dictionary of Occupational Titles. The vocational expert identified jobs including office helper and photocopy machine operator and explained that the Dictionary did not address certain limitations, such as overhead reaching, handedness, or neck movement. The court held that the expert’s experience supplied substantial evidence and that no unresolved conflict required additional explanation. The court also rejected Yacoobali’s argument concerning pushing and pulling with the left upper extremity.

Disposition

The court denied Yacoobali’s motion for summary judgment and granted Saul’s cross-motion for summary judgment. The court affirmed the ALJ’s decision, directed the clerk to enter judgment in favor of the defendant, and ordered the case closed. Judge Haywood S. Gilliam, Jr. signed the order on March 20, 2020.