Scott T. v. Saul

Background

Scott T. applied for Social Security Disability Insurance and Supplemental Security Income benefits. After an earlier unfavorable decision was sent back for further proceedings, a second Administrative Law Judge issued a partially favorable decision. The ALJ awarded Supplemental Security Income beginning May 31, 2018, but denied Scott T.’s application for Social Security Disability Insurance benefits. The ALJ found that Scott T. was not disabled before May 31, 2018, but became disabled on that date because of his advanced age.

The ALJ found that Scott T. could perform a limited range of light work. The restrictions included lifting 20 pounds occasionally and 10 pounds frequently, sitting for up to six hours with limits on continuous sitting, and standing and walking for four hours during an eight-hour workday. The ALJ also imposed restrictions on climbing and other postural activities. Relying on vocational-expert testimony, the ALJ found that a person with those restrictions could perform jobs such as office helper, hand packer, or small-products assembler.

Scott T. sought judicial review under 42 U.S.C. § 405(g). He moved for summary judgment, which asks the court to rule based on the administrative record without a trial. The Commissioner cross-moved to affirm the administrative decision.

Dr. Bader’s opinion

Dr. Semon Bader, who had performed surgery on Scott T.’s left ankle and later examined him, completed a work-ability assessment. Dr. Bader stated that Scott T. could lift or carry 30 pounds, stand two to four hours per day, and occasionally perform several postural activities. He also stated that pain and functional limitations would interfere with work tasks about 20 percent of the day.

The ALJ gave Dr. Bader’s opinion partial weight. The ALJ adopted or incorporated some standing, walking, and postural restrictions but imposed more restrictive lifting and sitting limits. The ALJ rejected the portion concerning interference with work tasks, relying in part on the lack of significant objective evidence and the absence of documented medication side effects or mental or behavioral abnormalities.

The court noted that Dr. Bader’s opinion was contradicted by other medical opinions, so the ALJ needed specific and legitimate reasons supported by substantial evidence to reject the disputed portion. The court nevertheless upheld the ALJ’s decision. The ALJ had found that Scott T.’s reports of pain were not entirely credible, and Scott T. did not challenge that finding. Because the disputed portion of Dr. Bader’s opinion relied on Scott T.’s subjective pain complaints, the court held that the ALJ could disregard that portion. The court also stated that any error in focusing on medication side effects and mental abnormalities rather than pain was harmless because the unchallenged credibility finding independently undermined the opinion’s pain-related limitations.

Dr. Shrestha’s opinion

Dr. Smriti Shrestha, another treating physician, stated that Scott T. could stand or walk only one to two hours in an eight-hour day and for 14 minutes at a time. She also described restrictions on sitting, lifting, carrying, postural activities, pushing and pulling, and the amount of time pain and medication side effects would interfere with work tasks.

The ALJ gave Dr. Shrestha’s opinion partial weight. The ALJ found that the general restrictions on standing, walking, and postural activities were consistent with Scott T.’s medical history and treatment records. But the ALJ found insufficient support for the more restrictive sitting, manipulative, and other limitations and gave greater weight to the Social Security medical consultants’ opinions.

The court held that the ALJ did not err. Although the ALJ did not repeat every reason in the section specifically discussing Dr. Shrestha’s opinion, the decision as a whole reviewed the medical evidence in detail. The court cited records showing mild or controlled pain, normal muscle strength and tone, normal or mildly antalgic gait, intact sensation, minimal tenderness, mild degenerative changes, and improvement with physical therapy. The court also relied on the unchallenged finding that Scott T.’s pain reports were not entirely credible. It concluded that the ALJ gave specific and legitimate reasons for rejecting the disputed limitations, including the opinion that pain would interfere with work tasks more than 30 percent of the day.

Ruling

The court applied the substantial-evidence standard, under which it could not replace the Commissioner’s judgment when the record reasonably supported more than one conclusion. Judge Ryu denied Scott T.’s motion for summary judgment and granted the Commissioner’s cross-motion. The court directed the clerk to enter judgment for the Commissioner and against Scott T. and to close the case.