Bradbury v. Berryhill

Background

Glenn D. Bradbury applied for Title II disability insurance benefits, alleging disability from neck and back pain and depression. The Social Security Administration denied the claim, and Administrative Law Judge Michael A. Cabotaje later found that Bradbury was not disabled. The administrative law judge determined that Bradbury had severe cervical and lumbar degenerative disc disease, but that his depression was not severe. The judge found that Bradbury had the residual functional capacity—the most he could still do despite his impairments—to perform limited light work, including lifting no more than 15 pounds and avoiding certain climbing, bending, crouching, crawling, and workplace-hazard exposures. The judge concluded that Bradbury could not perform his past work but could perform other jobs, including document preparer, food and beverage order clerk, and office addresser.

Arguments and analysis

Bradbury challenged the administrative law judge’s treatment of the opinion of Michael T. Young, his treating physician. Young stated that Bradbury could sit and stand or walk for only 20 minutes at a time and for about two hours total in an eight-hour workday. Young also stated that Bradbury could rarely move his neck in several directions and needed to rest his head or neck every two hours. The administrative law judge discounted these limitations as internally inconsistent, inconsistent with the reports of treating physician Mark H. Luoto, and unsupported by Bradbury’s testimony.

The court rejected those reasons. It held that Luoto’s reports, which focused on lifting, bending, and stooping for workers’ compensation purposes, did not contradict Young’s more detailed assessment of neck limitations. The court also held that Young’s opinion was not internally inconsistent when read in context: Young’s statement that Bradbury did not need to lie down concerned sitting, standing, and walking, while the later statement about resting his neck addressed the cervical impairment. The court found that the neck restrictions were supported by other evidence, including medical records and Bradbury’s testimony. It further held that the administrative law judge incorrectly stated that Bradbury had not complained about problems moving his head or neck.

The court also found that the administrative law judge did not adequately address acknowledged limitations that could result from Bradbury’s pain, pain disorder, medications, or mental-health conditions. The judge discussed whether the limitations were caused by depression or pain but did not analyze how limitations greater than mild would affect Bradbury’s ability to sustain work. The court said the administrative law judge could give Young’s opinion controlling weight or identify clear and convincing reasons for rejecting it. Because the case was being remanded, the court did not reach Bradbury’s arguments about the questions posed to the vocational expert.

Disposition

Judge Orrick granted Bradbury’s motion for summary judgment, denied the Commissioner’s motion for summary judgment, and remanded the case for further proceedings consistent with the order. The court did not award benefits or make a final determination that Bradbury was disabled.