Jean T. v. Commissioner of Social Security
- Donna Ryu
- 4:19-cv-07738
- U.S. District Court · Northern District of California
- 13
In Linda Jean T. v. Andrew Saul, Judge Ryu granted in part and denied in part Linda Jean T.’s motion, finding errors and remanding for further proceedings.
Linda Jean T.’s application for Supplemental Security Income benefits must receive further administrative consideration; the Commissioner’s disability decision was not affirmed in full.
What happened
In Linda Jean T. v. Andrew Saul, Linda Jean T. asked the court to reverse the decision denying her application for Supplemental Security Income benefits. The administrative law judge had found that she was not disabled and that she could perform several jobs despite bipolar disorder.
The court upheld the administrative law judge’s reasons for discounting opinions from treating providers Dr. Brinda Krishnan and Daniel R. Model. It also upheld the reasons for discounting Linda Jean T.’s testimony about the severity of her symptoms. But the court found that the administrative law judge failed to address several work-related limitations identified by state agency consultants F. Mateus and Joseph A. Shaver, or to explain why those limitations were rejected.
Judge Ryu granted in part and denied in part Linda Jean T.’s motion for summary judgment and remanded the matter for further proceedings. The court did not decide that Linda Jean T. was entitled to benefits.
The detailed version
- Jean T. v. Commissioner of Social Security · No. 4:19-cv-07738
- Donna Ryu
- May 11, 2021
Background
Linda Jean T. applied for Supplemental Security Income benefits under Title XVI of the Social Security Act, alleging disability from bipolar disorder. The Social Security Administration denied the application initially and on reconsideration. After a hearing, an administrative law judge (ALJ) found that Linda Jean T. had bipolar disorder but retained the residual functional capacity (RFC)—the abilities she could still use in a work setting—to perform work with specified physical and mental restrictions. Based on vocational-expert testimony, the ALJ concluded that she could perform jobs including Laundry Worker II, Furniture Cleaner, Remnant Sorter, and Laundry Worker. The Appeals Council denied review, and Linda Jean T. sought review under 42 U.S.C. § 405(g).
The parties filed cross-motions for summary judgment. Linda Jean T. argued that the ALJ improperly evaluated the medical opinions and her testimony about her symptoms. The Commissioner sought affirmance of the administrative decision.
Medical-opinion evidence
The court rejected Linda Jean T.’s challenge to the ALJ’s treatment of treating psychiatrist Dr. Brinda Krishnan’s opinion. Dr. Krishnan assessed significant limitations related to attention, attendance, completing a normal workday and workweek, responding to supervisors, and interacting with coworkers. The ALJ found that opinion unpersuasive because it was unsupported by the record as a whole and inconsistent with contemporaneous treatment notes, including largely normal mental-status examinations. The court held that these were specific and legitimate reasons for discounting the opinion, particularly because Dr. Krishnan’s own notes did not support the limitations she assessed.
The court also upheld the ALJ’s rejection of treating psychologist Daniel R. Model’s opinion. The ALJ found the opinion inconsistent with largely normal mental-status findings and normal daily activities, and found it equivocal because it described possible effects of symptoms without translating them into specific work-related functional limits. The court agreed that these were specific and legitimate reasons.
The court reached a different conclusion concerning the opinions of state agency consultants F. Mateus, M.D., and Joseph A. Shaver, Ed.D. Those consultants found moderate limitations in several areas, including interacting with coworkers, accepting instructions and responding to criticism from supervisors, maintaining regular attendance, working according to a schedule, and completing a normal workday and workweek without psychologically based interruptions. The ALJ’s RFC addressed some limitations, including limitations on complex tasks and public interaction, but did not address several of the other moderate limitations. The court held that, if the ALJ rejected those portions of the consultants’ opinions, the ALJ was required to give reasons supported by specific evidence and failed to do so.
Subjective symptom testimony
The ALJ found that Linda Jean T.’s medically determinable impairments could reasonably cause her alleged symptoms but concluded that her statements about their intensity and limiting effects were not entirely consistent with the record. Because the ALJ did not identify affirmative evidence of malingering, the ALJ needed specific, clear, and convincing reasons to discount her testimony.
The court held that the ALJ provided legally sufficient reasons based on largely normal mental-status examinations, conservative treatment, improvement and stabilization with treatment, and inconsistent medication compliance. The court found that the ALJ’s discussion of daily activities by itself was not a legally sufficient reason because the ALJ did not make the required specific findings about whether those activities transferred to a work setting. Nevertheless, the court concluded that the daily-activities discussion supported the overall symptom evaluation and that the ALJ did not err in discounting the testimony.
Disposition
The court granted in part and denied in part Linda Jean T.’s motion for summary judgment and remanded the matter for further proceedings consistent with the opinion. The ruling required further consideration of the limitations identified by Dr. Mateus and Dr. Shaver; it did not award benefits or decide that Linda Jean T. was disabled.
Read the full 13-page opinion on CourtListener, the free public archive maintained by the Free Law Project.