Jennifer H. v. Saul

Background

Jennifer H. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying her claim for Disability Insurance Benefits. She alleged disability beginning January 1, 2016. The administrative law judge found that she had severe impairments including degenerative disc disease, obesity, asthma, depression, anxiety, and post-traumatic stress disorder, but concluded that she was not disabled.

The administrative law judge determined that Jennifer H. had the residual functional capacity—the most she could still do despite her impairments—to perform medium work with several restrictions. She could frequently climb, balance, stoop, crouch, and crawl; could have only occasional exposure to certain environmental conditions; was limited to simple tasks with occasional changes in routine; could not interact with the public; could have occasional interaction with coworkers and supervisors; and could be off task for 10 percent of a typical workday. Because she had no past relevant work, the administrative law judge relied on vocational-expert testimony and found that she could perform jobs existing in significant numbers in the national economy.

The parties filed cross-motions for summary judgment. Jennifer H. argued that the administrative law judge improperly evaluated the 2018 residual functional capacity assessment by Nurse Practitioner Helen Carlile, incorrectly found that her impairments did not meet or equal a listed impairment, and adopted a residual functional capacity unsupported by substantial evidence.

Medical-opinion evidence

The court held that substantial evidence supported the administrative law judge’s evaluation of Carlile’s opinions. The administrative law judge gave great weight to Carlile’s 2016 opinion, which described less severe limitations, but found Carlile’s 2018 opinion—which described marked limitations in working with others, completing a normal workday and workweek, interacting with the public, and maintaining socially appropriate behavior—not persuasive.

The court relied on treatment notes showing generally unremarkable mental-status examinations, reports that medication and therapy were helpful, periods of work and increased activity, improved mood and sleep, reduced alcohol use, care for Jennifer H.’s daughter, and progress in self-care and coping with trauma. The court concluded that the treatment records did not show a worsening of her mental-health symptoms between 2016 and 2018. It therefore upheld the administrative law judge’s reasons for discounting the more restrictive 2018 opinion.

Listed impairments

The administrative law judge found that Jennifer H.’s mental impairments did not meet or medically equal Listings 12.04, 12.06, or 12.15, concerning depressive and related disorders, anxiety and obsessive-compulsive disorders, and trauma- and stressor-related disorders.

The court upheld that conclusion. The administrative law judge found moderate—not marked or extreme—limitations in understanding, remembering, or applying information; interacting with others; concentrating, persisting, or maintaining pace; and adapting or managing oneself. The court stated that the administrative law judge supported those findings with evidence including normal mental-status findings, enrollment in a graduate program, relationships with close friends, care for her daughter, reading and watching television, following instructions, preparing meals, and managing personal and household needs. The court also noted that Jennifer H.’s argument relied primarily on Carlile’s 2018 opinion, which the court had already found was properly discounted.

Residual functional capacity

The court also found substantial evidence supporting the residual functional capacity. It agreed that the administrative law judge reasonably considered the treatment records, objective findings, Jennifer H.’s reported activities, her part-time work, her ability to care for her daughter, and her treatment history. The court concluded that this evidence was inconsistent with the more severe limitations she alleged, including being off task for a substantial part of the workday and having repeated work absences.

The court rejected Jennifer H.’s argument that the 10-percent off-task limitation was arbitrary, stating that she had not shown how including that limitation harmed her. The court also explained that residual functional capacity is an administrative finding based on the record as a whole and need not match any one medical opinion.

Disposition

Judge Thomas S. Hixson denied Plaintiff’s motion for summary judgment and granted Defendant’s cross-motion for summary judgment. The court affirmed the administrative law judge’s decision and stated that the Clerk would terminate the case after entry of a separate judgment.