Young v. Saul

Background

Marcell Young sought judicial review of the Commissioner of Social Security’s final decision denying his claims for disability benefits and Supplemental Security Income. An administrative law judge found that Young had schizophrenia and alcohol abuse, but determined that he could perform simple, unskilled work and that jobs existed in significant numbers that he could perform. The administrative law judge therefore concluded that Young was not disabled.

Young and the Commissioner filed cross-motions for summary judgment. Young argued that the administrative law judge made several errors in evaluating his work activity, impairments, medical evidence, testimony, residual functional capacity, and the availability of other work.

Court’s Analysis

The court upheld the finding that Young’s work from November 2016 through July 2017 was substantial gainful activity. The court also found that any error concerning Young’s October 2017 garbage-collection work was harmless. However, the court identified other errors that required further proceedings.

First, the administrative law judge failed to consider whether Young’s borderline intellectual functioning was a severe impairment and failed to account for it when assessing his residual functional capacity. The court did not rule that the impairment was necessarily severe, but held that the administrative law judge had to address it and consider its possible combined effects with Young’s schizophrenia.

Second, the court held that the administrative law judge improperly discounted opinions from nurse practitioner K. Lu Gilligan and therapist Teresa Shepard. The administrative law judge relied on general statements that the opinions conflicted with treatment notes and improvement on medication, but did not adequately consider their treating relationships, the evidence supporting their opinions, or the required factors for evaluating opinions from sources who are not acceptable medical sources.

Third, the court held that the administrative law judge improperly rejected the opinions and observations of Lesleigh Franklin and Dionne Childs. The reasons given for discounting their testing and conclusions were not specific and legitimate reasons supported by substantial evidence. The administrative law judge also failed to address portions of Franklin’s opinion concerning Young’s difficulty remembering and following instructions, low frustration tolerance, social-interaction problems, and coping skills.

The court further held that the administrative law judge improperly rejected Young’s testimony about his symptoms. Although the administrative law judge identified specific areas of testimony, he relied selectively on evidence showing improvement and failed to consider evidence of continuing hallucinations, paranoia, depression, sleep problems, and fluctuating symptoms.

The court also found that the administrative law judge failed to give adequate reasons for discounting statements from Young’s mother and uncle. Their statements were competent evidence about Young’s symptoms and daily functioning, and the administrative law judge did not identify sufficiently specific inconsistencies or explain how the evidence justified rejecting their testimony.

Finally, the court held that the residual functional capacity assessment was affected by these errors and by the failure to consider borderline intellectual functioning. The administrative law judge also failed to discuss testimony from a vocational expert who stated that a person with certain limitations described in the hearing hypotheticals would not be able to perform the relevant work or other work. Because the revised residual functional capacity could change whether the Medical-Vocational Guidelines applied, the step-five analysis also had to be reconsidered.

Disposition

The court concluded that outstanding evidentiary issues remained, including how to weigh the medical opinions and lay testimony and how those findings would affect the residual functional capacity and the step-five analysis. The court therefore remanded the action to the assigned administrative law judge for further proceedings rather than ordering an award of benefits.

The court granted Young’s motion for summary judgment, denied the Commissioner’s cross-motion for summary judgment, remanded the action for further proceedings, adjudicated all pending motions, and closed the case.