Susan C. v. Kijakazi

Background

Susan C. sought review under 42 U.S.C. § 405(g) of the Social Security Administration’s denial of her application for Disabled Widow Insurance benefits. The administrative law judge found that she had not engaged in substantial gainful activity since December 31, 2014, and had severe impairments including bradycardia, hypothyroidism, post-traumatic stress disorder, and bipolar disorder, type II. The administrative law judge determined that she had the residual functional capacity—the most she could still do despite her limitations—to perform medium work with specified restrictions. He found that she could perform her past work as a laboratory assistant and, alternatively, other jobs such as hospital cleaner, industrial cleaner, and automobile detailer.

Susan C. moved for summary judgment, asking the court to reverse the denial of benefits. Kijakazi filed a cross-motion for summary judgment, asking the court to affirm the administrative decision.

Medical opinion evidence

The administrative law judge gave little weight to the opinions of Susan C.’s treating psychiatrist, Dr. Wilson. He reasoned that Dr. Wilson’s extreme limitations were inconsistent with Susan C.’s daily activities and part-time work, and that Dr. Wilson’s estimated 1989 disability date conflicted with Susan C.’s alleged onset date and work history.

The court held that the daily-activity and part-time-work reasoning was not sufficiently specific and was not supported by substantial evidence. Susan C. prepared simple food, received help from a housekeeper, shopped infrequently and often with a friend, and attended church once a week. She worked only six to eight hours per week and received help from friends and family during severe depressive episodes. The court found that these activities did not show she could maintain the full-time, mandatory schedule considered by Dr. Wilson.

The court found that the inconsistency involving the 1989 date was a sufficient reason to discount Dr. Wilson’s estimated disability date, but not the rest of Dr. Wilson’s opinions. Because the administrative law judge did not give sufficient reasons for rejecting the remaining opinions, the court found error requiring remand.

Susan C.’s testimony

The administrative law judge discounted Susan C.’s testimony based on her part-time vacation-rental work, her daily activities, and improvement after mental-health treatment. The court held that none of these reasons, alone or together, satisfied the requirement for specific, clear, and convincing reasons supported by substantial evidence.

The court explained that part-time work performed with assistance did not establish the ability to work full-time. It also found that the administrative law judge did not identify which parts of Susan C.’s testimony conflicted with which daily activities. Although the record showed some improvement after hospitalization, electroconvulsive therapy, and medication changes, the court found that the improvement was temporary and that the record also showed later worsening. The court further held that describing treatment as conservative or limited was not enough because the administrative law judge did not identify more aggressive treatment that was available and appropriate.

Remedy and disposition

The court considered whether to order immediate payment of benefits under the credit-as-true doctrine, which can require an agency to accept improperly rejected evidence when specified conditions are met and the record leaves no serious doubt about disability. The court concluded that although the administrative law judge failed to fully and fairly develop the record, it was not clear that Susan C. would necessarily be found disabled. The court therefore determined that remand for further administrative proceedings was appropriate.

The court granted Susan C.’s motion, denied Kijakazi’s cross-motion, reversed the administrative law judge’s decision, and remanded the case for further administrative proceedings consistent with the order. The court stated that a separate judgment would be entered and that the clerk would terminate the case.