Terrell W. v. Saul

Background

Terrell W. sought disability insurance benefits under Title II of the Social Security Act, alleging disability beginning August 1, 2014. The claim involved carpal tunnel syndrome, lateral epicondylitis (tennis elbow), osteoarthritis, obesity, high blood pressure, and numbness in both arms. After an administrative hearing, Administrative Law Judge Thomas J. Gaye found that the impairments were severe but did not meet or equal a listed impairment. The judge determined that Terrell W. had the residual functional capacity (the most a person can still do despite limitations) to perform light work with restrictions, including frequent manipulation with both hands and frequent reaching on the right side. Based on vocational-expert testimony, the judge found that Terrell W. could perform past work as a department store sales representative and therefore was not disabled.

Issues and analysis

The court reviewed the Commissioner’s decision under the substantial-evidence standard, which requires enough relevant evidence that a reasonable person could accept the finding, and also reviewed whether the administrative law judge applied the correct legal standards.

The court held that the administrative law judge improperly rejected medical opinions supporting a limitation to occasional overhead reaching with both arms. The opinions included one from examining physician Dr. Sharma and opinions from treating physicians. The administrative law judge reasoned that mild left-side tennis elbow and a lack of objective evidence of a shoulder impairment did not support a left-side reaching limitation. The court found that the judge did not identify adequate medical evidence supporting that conclusion and instead relied on his own interpretation of the medical findings. The court also explained that the opinion of a non-examining physician could not, by itself, supply the required substantial evidence.

The Commissioner argued that any error was harmless because Terrell W. could still perform the department store sales representative job even with occasional overhead reaching. The court rejected that argument. The vocational expert had not been asked to consider a limitation to occasional reaching with both arms, and the court found it was not obvious that the department store sales representative job involved only occasional overhead reaching. The error therefore could have affected the finding at the step assessing whether Terrell W. could perform past relevant work.

Disposition

The court GRANTED Terrell W.’s motion for summary judgment and DENIED the Commissioner’s cross-motion for summary judgment. It remanded the case for further proceedings consistent with the order. The court declined to decide Terrell W.’s additional arguments.