Jaimie V.W. v. Saul

Background

Jaimie V.W. applied for supplemental security income, alleging disability beginning June 1, 2017. After a hearing at which Jaimie V.W. and a vocational expert testified, the Administrative Law Judge found that she had severe impairments including major depressive disorder, post-traumatic stress disorder, opioid use disorder treated through a methadone program, and cocaine abuse.

The Administrative Law Judge found that Jaimie V.W. could perform work at all exertional levels, subject to limits involving hazardous machinery and heights, simple and repetitive tasks, low stress, limited decision-making and workplace changes, no interaction with the public, and occasional interaction with coworkers. Because she had no past relevant work but could adjust to jobs existing in significant numbers in the national economy, the Administrative Law Judge found her not disabled.

Jaimie V.W. moved for summary judgment, arguing that the Administrative Law Judge erred in evaluating medical evidence, her credibility, her residual functional capacity, the step-five work finding, and evidence submitted to the Appeals Council. The Commissioner filed a cross-motion for summary judgment, arguing that the decision was correct.

Analysis

The court reviewed the Commissioner’s final decision to determine whether it contained legal error or was unsupported by substantial evidence. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

The court held that the Administrative Law Judge properly evaluated the medical opinions under the newer Social Security regulations applicable to Jaimie V.W.’s claim. Those regulations require consideration of factors including supportability and consistency, and they do not give controlling weight or automatic deference to treating physicians. The court found that the opinions of Kyle Van Gaasbeek, M.D., R. Ferrell, M.D., John Petzelt, Ph.D., J. Collado, M.D., K. Rudito, M.D., and I. Ocrant, M.D. were adequately supported and consistent with the record.

The court also held that the Administrative Law Judge gave sufficient reasons for finding Jaimie V.W.’s statements about the severity of her symptoms less persuasive. The reasons included gaps in treatment, the absence of mental-health medication, her statement that her physical health was okay, daily activities, the lack of recorded panic attacks, differences in her statements about reading, and treatment records showing generally normal concentration, cognition, insight, and judgment. The court separately found that the Administrative Law Judge did not improperly rely on Dr. Leslie Morey’s statement concerning Jaimie V.W.’s self-presentation in evaluating credibility.

The court concluded that the residual functional capacity finding was supported by substantial evidence. It found that statements from Buzza, Kevin Lagor, and Jennifer Spevak provided diagnoses but did not describe what Jaimie V.W. could still do or what specific work restrictions she had, so the Administrative Law Judge was not required to treat those statements as medical opinions for the residual functional capacity analysis. Because the residual functional capacity finding was supported, the court also rejected the challenge to the step-five conclusion.

Finally, the court considered the psychological evaluation submitted to the Appeals Council. The court found that the evaluation was consistent with the Administrative Law Judge’s finding that Jaimie V.W. had impairments and needed work limitations but was not disabled. It therefore concluded that the additional evidence did not require a remand.

Disposition

Judge Sallie Kim denied Jaimie V.W.’s motion for summary judgment and granted the Commissioner’s cross-motion for summary judgment.