T.J. v. Saul

Background

T.J. sought judicial review of the Commissioner of Social Security’s final decision denying her application for disability-insurance benefits under Title II of the Social Security Act. She alleged disability beginning January 25, 2016, based on post-traumatic stress disorder, anxiety disorder, depression, degenerative disease, osteoarthritis, chronic-fatigue syndrome, and fibromyalgia.

The administrative law judge found that T.J. had not engaged in substantial gainful activity since the alleged onset date and had several severe impairments, including post-traumatic stress disorder, anxiety, depressive and borderline-personality disorders, chronic-fatigue syndrome, fibromyalgia, and osteoarthritis. The administrative law judge found that her impairments did not meet or equal a listed impairment, assessed her residual functional capacity as permitting light work with postural, safety, and public-contact restrictions, found that she could not perform her past relevant work, and concluded at the final step that she could perform jobs such as office clerk, hand packager, and inspector.

Issues and Analysis

The court reviewed whether the administrative law judge’s decision was legally correct and supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate.

The court held that the administrative law judge improperly gave only partial weight to the opinion of T.J.’s treating psychologist, Penelope McAlmond-Ross. Because that opinion conflicted with the state consultants’ opinions, the administrative law judge had to give specific and legitimate reasons supported by substantial evidence for rejecting part of it. The court found that the administrative law judge did not support the rejection of the psychologist’s assessment of T.J.’s ability to adapt and did not adequately explain why T.J.’s appropriate attire and grooming contradicted the psychologist’s other findings.

The court also held that the administrative law judge needed to reconsider the step-three determination—whether T.J.’s impairments, alone or in combination, met or equaled a listed impairment—because the medical-opinion error affected that analysis. A boilerplate finding was insufficient without an adequate evaluation of the relevant evidence and combined effects of the impairments.

The court held that the administrative law judge improperly rejected T.J.’s testimony about the intensity and effects of her symptoms. The administrative law judge did not identify the specific testimony found not credible or provide sufficiently clear and convincing reasons for rejecting it. The court also found that the administrative law judge did not address T.J.’s explanation for declining psychotropic medication and relied on isolated evidence of improvement despite records describing continuing serious difficulties.

The court held that the administrative law judge improperly gave only partial weight to T.J.’s husband’s statement. The husband’s lack of medical training was not a specific and relevant reason to disregard his observations as a lay witness, and the administrative law judge provided no other reasons.

Because the residual-functional-capacity finding depended on the assessments of the medical opinions and other evidence, the court also remanded for reconsideration of the step-five finding that jobs were available in the national economy.

Disposition

The court chose a remand for further administrative proceedings rather than an immediate award of benefits, finding that further proceedings could remedy defects in the original administrative process. It granted T.J.’s motion for summary judgment, denied the Commissioner’s cross-motion for summary judgment, and remanded for further proceedings consistent with the order.