Soeun M. v. Saul
- Thomas Hixson
- 3:19-cv-04518
- U.S. District Court · Northern District of California
- 26
In Soeun M. v. Saul, Judge Hixson denied disability claimant Soeun M.’s motion and granted Saul’s motion for summary judgment.
Soeun M., whose claim for disability benefits remains denied, and Andrew Saul, whose agency decision was upheld through the court’s grant of his cross-motion for summary judgment.
What happened
Soeun M. v. Saul concerned Soeun M.’s request for court review of the Social Security Administration’s denial of her disability-benefits claim. She argued that the administrative law judge had misunderstood the medical evidence, her symptoms, and her ability to work.
The court rejected those arguments. It found substantial evidence supporting the administrative law judge’s findings that Soeun M.’s physical impairments were not severe, her mental impairments did not meet the listed requirements for disability, and she could perform simple, routine work requiring no more than basic English. The court also found no error in the treatment of the medical opinions, her reported symptoms, or the vocational expert’s testimony.
Judge Hixson denied Soeun M.’s motion for summary judgment and granted Andrew Saul’s cross-motion. The court stated that a separate judgment would be entered and that the Clerk would terminate the case.
The detailed version
- Soeun M. v. Saul · No. 3:19-cv-04518
- Thomas Hixson
- Sept. 1, 2020
Background
Soeun M. sought judicial review under 42 U.S.C. § 405(g) of the final decision denying her disability benefits. The administrative law judge found that she had severe depressive, anxiety, and post-traumatic stress disorders, but no severe physical impairment. The judge determined that her impairments did not meet or medically equal a listed impairment. He assessed a residual functional capacity—the most a person can still do despite her impairments—for work at all exertional levels, limited to simple, routine tasks and work requiring no more than basic English. Although she could not return to her past work, the administrative law judge found that she could perform other jobs existing in significant numbers in the national economy.
Arguments and Analysis
Soeun M. argued that the administrative law judge improperly found her physical impairments non-severe, failed to consider medical equivalence, improperly weighed the opinions of Dr. Arpaci and Dr. Kalich, discounted her symptom statements without adequate support, assessed an unsupported residual functional capacity, relied on an incomplete hypothetical question to the vocational expert, and failed to apply Social Security Ruling 85-15.
The court concluded that substantial evidence supported the administrative law judge’s findings. The medical records showed very mild lumbar changes, no thoracic-spine abnormality, generally little or no reported pain, and treatment that supported finding the physical impairments non-severe. The court also found that the administrative law judge gave adequate reasons for assigning little weight to portions of the opinions from Dr. Arpaci, Dr. Kalich, Dr. Cohen, Dr. Guh, and physician assistant Rouche. The court determined that Dr. Kalich’s testing and conclusions were internally inconsistent and that Dr. Arpaci’s opinion linked much of the work-related impairment to physical problems the administrative law judge found non-severe.
The court further held that Soeun M. had not presented a specific medical-equivalence theory to the administrative law judge or the Appeals Council and had not identified a listing that her impairments met or equaled. It found that the administrative law judge adequately considered the evidence supporting the symptom finding, and that Soeun M. had waived challenges to some of the stated reasons by failing to address them. The court treated the administrative law judge’s statement that Soeun M. was unable to communicate in English as a typographical error, relying on the stated limitation to work requiring no more than basic English. It also found no error concerning Social Security Ruling 85-15.
Disposition
Judge Thomas S. Hixson denied Soeun M.’s motion for summary judgment and granted Andrew Saul’s cross-motion for summary judgment. The court stated that it would enter a separate judgment and that the Clerk would terminate the case.
Read the full 26-page opinion on CourtListener, the free public archive maintained by the Free Law Project.