Turner v. Berryhill

Background

Jacqueline Renee Turner sought judicial review of an administrative law judge’s denial of her applications for disability insurance benefits and supplemental security income. The administrative law judge found that Turner had several severe impairments, including lumbar-spine degenerative disc disease, right-knee osteoarthritis, a prior meniscus tear, obesity, major depressive disorder, and anxiety disorder. The judge found that Turner could not perform her past work but could perform other jobs in significant numbers, and therefore concluded that she was not disabled from June 30, 2011, through March 30, 2018.

Turner challenged the decision on two principal grounds. First, she argued that the administrative law judge lacked legally sufficient reasons for rejecting the work-related limitations described by examining psychologist Maria T. Holden and examining psychiatrist Charles DeBattista. Second, she argued that the judge failed to account for her lengthy work history when evaluating her credibility. The Commissioner argued that the residual functional capacity—the most a person can still do despite her impairments—was supported by substantial evidence and that the judge properly rejected the examining doctors’ assessments.

Court’s Analysis

The court held that the administrative law judge incorrectly found Turner’s panic disorder was not medically determinable. The judge had attributed the diagnosis to a social worker and treated it as based only on Turner’s self-reports. The court found that the record showed Turner’s treating psychiatrist, Thomas Yun, M.D., diagnosed the panic disorder in 2014.

The court also held that the judge gave inadequate reasons for assigning little weight to the opinions of Drs. Holden and DeBattista. The judge relied on observations such as Turner’s being cooperative, neatly groomed, coherent, able to complete paperwork, and able to perform activities such as attending church, running errands, cooking, and doing household chores. The court found that these facts did not logically or substantially support rejecting the doctors’ opinions about Turner’s work-related mental limitations.

The court further found that the judge improperly gave great weight to the opinions of non-examining state-agency consultants Anna Franco, Psy.D., and Sidney Gold, M.D. The court explained that opinions from non-examining doctors cannot, by themselves, provide substantial evidence for rejecting examining doctors’ opinions. The court concluded that the mental-health portions of the residual functional capacity were not supported by substantial evidence and that the judge had not addressed supporting opinions from Turner’s treating doctors, Ryan Estevez, M.D., and Dr. Yun.

The court declined to decide Turner’s separate argument about her work history because it was already remanding the case for further proceedings.

Ruling

The court reversed the administrative law judge’s Step Two finding concerning Turner’s panic disorder. It ordered the administrative law judge to give controlling weight to the common limitations identified in the opinions of Drs. Holden and DeBattista, as well as the opinions of Drs. Estevez and Yun, while fully and fairly developing the record and reconciling any inconsistencies between those opinions.

The court granted Plaintiff’s Motion for Summary Judgment, denied Defendant’s Motion for Summary Judgment, and remanded the case for further proceedings consistent with the court’s instructions. The administrative law judge was also instructed to consider the other issues Turner raised in her briefing and modify the decision as appropriate.