Williams v. Berryhill

Background

Cedric Williams sought judicial review under 42 U.S.C. § 405(g) of the Commissioner’s denial of his application for Title XVI disability benefits. He applied on July 31, 2012, alleging that his disability began that day. The Social Security Administration denied the application initially and on reconsideration. After a hearing, an administrative law judge denied the claim in 2014. In an earlier round of this case, the court remanded the matter for further proceedings.

Williams testified at another hearing in 2018, and another administrative law judge again found that he was not disabled. The Appeals Council denied review, making that decision the Commissioner’s final decision. Williams then filed this action. He moved for summary judgment, and the Commissioner filed a cross-motion for summary judgment.

Legal standard

The court could reverse the Commissioner’s decision if it was based on legal error or was not supported by substantial evidence. Substantial evidence means more than a small amount of evidence but less than a preponderance; it is evidence that a reasonable person could accept as adequate support for the conclusion.

Disability claims are evaluated through a five-step process. Among other things, the process considers whether the claimant has a severe impairment, whether the impairment meets a listed impairment, the claimant’s remaining ability to work, and whether the claimant can perform past or other work.

Medical opinions

Williams argued that the administrative law judge improperly evaluated the medical evidence, his statements, the listed-impairment analysis, his residual functional capacity, and his ability to perform past and other work. Because the court concluded that an immediate award of benefits was appropriate, it addressed only the arguments supporting that result.

The court found that the administrative law judge failed to explain what weight, if any, was given to Dr. Saini’s opinion. Dr. Saini’s treatment records described Williams’s low attention and concentration, anxiety and social anxiety, difficulty adapting to a work environment, emotional distress, and difficulty controlling anger. The court held that the administrative law judge failed to give legally sufficient reasons for rejecting that opinion and therefore treated it as accepted.

The court also found that the reasons given for assigning little weight to Dr. Wiebe’s opinions were legally insufficient. Dr. Wiebe conducted three evaluations and reported marked to extreme limitations in many areas of mental functioning. The court rejected the administrative law judge’s reliance on Williams’s intermittent work history, Dr. Bodepudi’s less comprehensive 2012 evaluation, Dr. Rana’s physical examination, and Williams’s inconsistent mental-health treatment. The court noted that intermittent work did not necessarily rule out disability and that Williams’s housing history and other circumstances made inconsistent treatment understandable. It therefore treated Dr. Wiebe’s opinion as accepted as well.

Listed impairments and remedy

The administrative law judge had found that Williams’s mental impairments did not meet or equal a listed impairment because he lacked one extreme limitation or two marked limitations in the required areas of mental functioning. After crediting Dr. Wiebe’s opinion as true, however, the court found that Williams met the requirements for Listings 12.03, 12.04, and 12.06, concerning psychotic disorders; depressive, bipolar, and related disorders; and anxiety and obsessive-compulsive disorders.

The court concluded that no unresolved issues remained and that crediting the medical opinions required a finding of disability. Meeting a listing at the third step of the disability process entitled Williams to benefits.

Disposition

The court GRANTED Williams’s motion for summary judgment, DENIED the Commissioner’s cross-motion for summary judgment, and REMANDED the case to the Commissioner under sentence four of 42 U.S.C. § 405(g) for an immediate award of benefits. Judge Kandis Westmore entered the order on November 30, 2020.