A.L. v. Saul

Background

A.L. sought judicial review of the Commissioner of Social Security’s decision denying her applications for disability insurance benefits and supplemental security income. She alleged disability beginning November 23, 2014, based on bipolar disorder, anxiety, depression, left-leg tightness, and numbness in part of her left foot. The administrative law judge found severe impairments consisting of mild cervical degenerative disc disease, headaches, and bipolar disorder. The judge determined that A.L. could perform light work with several restrictions, including simple routine tasks, only occasional public contact, and work that was task-oriented rather than at a production pace. The judge concluded that A.L. could not perform her past work but could perform other jobs, including small product assembler, packing-line worker, and laundry folder.

The parties filed cross-motions for summary judgment. A summary-judgment motion asks the court to rule based on the existing record when there is no genuine dispute requiring a trial. The court reviewed whether the Commissioner’s decision was supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate, and whether the correct legal standards were used.

Treating psychiatrist’s opinions

The court held that the administrative law judge did not properly evaluate the opinions of A.L.’s treating psychiatrist, Daniel Haycraft, M.D. Dr. Haycraft identified limitations involving concentration, attendance, completing a normal workday, interacting with supervisors, and responding to workplace changes. Because Dr. Haycraft’s opinions conflicted with opinions from non-examining doctors, the administrative law judge needed to provide specific and legitimate reasons supported by substantial evidence for discounting them.

The court found that the administrative law judge did not address the required factors for evaluating a treating doctor’s opinion, such as the treatment relationship, supportability, consistency with the record, and the doctor’s specialization. The court also found that the reasons given were inadequate. Evidence concerning A.L.’s mental-health hospitalization, work absenteeism, anxiety, auditory hallucinations, self-harm thoughts, and difficulty responding to authority figures contradicted the administrative law judge’s conclusions. The court further held that A.L.’s hygiene at medical appointments, independent living, occasional activities with her son, and described caregiving responsibilities did not constitute substantial evidence that she could respond appropriately to supervisors or workplace changes.

A.L.’s testimony

The court also held that the administrative law judge did not give the required clear and convincing reasons for discounting A.L.’s testimony about auditory hallucinations, anxiety, mania, depression, and difficulty functioning at work and in everyday interactions. The administrative law judge relied on statements that medication was relatively effective and that A.L. was functioning despite hallucinations, but the court found that the cited records did not adequately support those conclusions. The court also found that the administrative law judge improperly relied on isolated periods of improvement, including playing softball, working more hours, obtaining another job, and attending programs, without adequately considering evidence that A.L.’s symptoms continued or worsened.

A.L.’s mother’s statements

A.L.’s mother, Cynthia Aultman, submitted statements describing A.L.’s difficulty staying in one job, leaving situations to avoid losing control, hearing voices, experiencing paranoia, and handling household and parenting responsibilities. The administrative law judge did not discuss those statements. The court held that this omission was not harmless because the administrative law judge had not adequately evaluated A.L.’s own testimony and had not provided a valid reason for disregarding the mother’s statements.

Vocational evidence and remand

The court found an apparent conflict between the vocational expert’s testimony and the occupational descriptions in the Dictionary of Occupational Titles. The administrative law judge limited A.L. to task-oriented work rather than production-paced work, but the vocational expert used a different understanding of production-paced work when estimating the number of available assembler and packing-line jobs. Those occupations involved assembly-line or conveyor-line work that appeared to fit the administrative law judge’s definition of production-paced work. The administrative law judge therefore needed to identify and resolve the conflict before relying on that testimony.

The court concluded that the errors were not harmless. Although the laundry-folder occupation did not have a production-pace requirement, the record identified only 2,400 such jobs nationwide, and the court stated that it was unclear whether that number was sufficient under the circumstances.

Disposition

The court granted A.L.’s motion for summary judgment, denied the Commissioner’s cross-motion for summary judgment, and remanded the matter for further proceedings. On remand, the administrative law judge must reevaluate Dr. Haycraft’s opinions, provide legally adequate reasons for discounting any part of those opinions or A.L.’s statements, reconsider A.L.’s residual functional capacity, and reassess whether specific jobs exist in substantial numbers that A.L. can perform. The court did not direct an award of benefits. Judge Virginia K. Demarchi ordered the entry of judgment and closure of the file.