Castaneda v. Berryhill

Background

Athziri Castaneda had been found disabled beginning October 3, 2012, based on affective mood disorder and major depressive disorder that prevented her from sustaining a normal 40-hour workweek. Following a continuing disability review, the Social Security Administration determined that she was no longer disabled as of April 15, 2016, because of medical improvement. That determination was upheld on reconsideration and after a hearing before an administrative law judge (ALJ).

The ALJ found that, beginning April 15, 2016, Castaneda could perform work at all exertional levels, subject to limits including simple, unskilled tasks; limited interaction with coworkers and supervisors; no interaction with the public; and the ability to maintain concentration, persistence, and pace for simple tasks. Relying on vocational-expert testimony, the ALJ found that Castaneda could perform jobs such as salvage laborer, laundry laborer, and fruit and vegetable packer. The Appeals Council denied review, and Castaneda sought review in the district court.

Issues

Castaneda argued that the ALJ’s finding of medical improvement was not supported by substantial evidence. She also argued that the ALJ’s residual functional capacity (RFC)—the most a person can do despite her impairments—was not supported by substantial evidence.

Court’s Analysis

The court explained that benefits may be terminated only when substantial evidence shows medical improvement that enables the claimant to engage in substantial gainful activity. During a continuing disability review, the ALJ must consider all current impairments in combination and determine their effect on the claimant’s ability to perform basic work activities.

The court found that the record documented schizophrenia diagnoses and hallucinations before and after the comparison point decision, which was the prior decision finding Castaneda disabled. Although the ALJ did not discuss in detail whether schizophrenia was a severe impairment, the court held that any such error was harmless. The ALJ had discussed Castaneda’s hallucinations and the evidence that they had improved by April 2016, and substantial evidence supported that conclusion.

The court reached a different conclusion about agoraphobia. The record included diagnoses and symptoms of agoraphobia before and after April 15, 2016, including evidence that Castaneda had difficulty going outside alone, using public transportation, and entering crowded public spaces. The ALJ noted some of this evidence but did not include agoraphobia in the analysis of whether Castaneda had developed additional impairments. The ALJ also provided little analysis and did not explain why the most recent evidence of agoraphobia should be discounted.

Because the court could not determine from the record that Castaneda did not have agoraphobia or that it was not a severe impairment, it concluded that the ALJ erred in finding medical improvement based only on affective mood disorder and major depressive disorder. The RFC was also unsupported because it did not account for limitations associated with agoraphobia.

Disposition

Judge Donna Ryu granted Castaneda’s motion for summary judgment in part and remanded the matter for further proceedings consistent with the opinion. The opinion’s conclusion does not separately state a disposition for the Commissioner’s cross-motion to affirm.