Margaret R. v. Berryhill

Background

Margaret R. applied for Social Security Disability Insurance benefits, alleging that she became disabled on September 29, 2013. An administrative law judge found that she had severe depression and anxiety but retained the ability to perform work with specified nonphysical limitations. The judge therefore found her not disabled. The Social Security Administration’s Appeals Council declined review, making the administrative law judge’s decision the Commissioner’s final decision.

Margaret R. asked the district court to reverse that decision. The Commissioner cross-moved for summary judgment, asking the court to affirm it.

Issues

Margaret R. argued that the administrative law judge improperly evaluated medical opinions, rejected her testimony, rejected testimony from her husband, and assessed whether she could perform other work.

Medical-opinion analysis

The court focused on the opinions of Dr. Debra Bunger, who treated Margaret R., and Dr. Aparna Dixit, who performed a consultative psychological evaluation. Both doctors identified significant limitations in Margaret R.’s social functioning.

The administrative law judge gave little weight to Dr. Bunger’s opinion, reasoning that it was internally inconsistent, inconsistent with Dr. Bunger’s treatment notes, and inconsistent with Margaret R.’s daily activities. The court rejected those explanations. The judge did not identify which limitations were allegedly inconsistent, and the Commissioner could not rely on explanations that the administrative law judge had not given in the decision. The treatment notes recorded generally normal cognitive findings but also consistently described paranoia, anxiety, difficulty trusting others, difficulty socializing, and difficulty leaving the house. The court found that those notes were consistent with significant social limitations. The court also found that Margaret R.’s occasional social activities, often while accompanied by family or friends and sometimes involving paranoia or medication, did not adequately undermine Dr. Bunger’s opinion.

The administrative law judge gave significant weight to most of Dr. Dixit’s opinion but rejected her assessment that Margaret R. was moderately limited in interacting with coworkers. The court found that the administrative law judge did not identify the supposed objective medical evidence contradicting that limitation. The court also found that the administrative law judge relied on the same inadequate analysis of Margaret R.’s daily activities. Because the opinions about social limitations were not contradicted by another physician, the administrative law judge needed clear and convincing reasons to reject them, and the court found that he had not provided those reasons.

Other arguments and disposition

The court did not reach Margaret R.’s arguments about the rejection of her testimony, the discounting of her husband’s lay testimony, or the step-five assessment. It found that the medical-opinion error was not harmless because a different evaluation of those opinions could affect other parts of the disability analysis, including the residual functional capacity and the treatment of the testimony.

The court granted Margaret R.’s motion for summary judgment and denied the Commissioner’s cross-motion. It directed the Clerk to enter judgment for Margaret R. against the defendant and close the case. On remand, the administrative law judge was instructed to revisit the relevant issues and make findings consistent with the order and applicable regulations.