Karl M. v. Kijakazi

Background

Karl M. sought review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying his application for Social Security Disability Insurance benefits. He alleged that he became unable to work in November 2017. An administrative law judge found that Karl M. had severe degenerative joint disease of the shoulders with symptoms of impingement, but determined that he retained the residual functional capacity to perform medium work with only occasional bilateral pushing and pulling using his upper extremities. Relying on vocational-expert testimony, the administrative law judge found that he could perform jobs including kitchen helper and hand packager.

Issues

Karl M. argued that the administrative law judge improperly evaluated his testimony about his symptoms and that the finding at the final step of the disability analysis was not supported by substantial evidence. The Commissioner moved to affirm the administrative decision.

Court’s Analysis

Because the administrative law judge did not find that Karl M. was malingering, the judge needed to give specific, clear, and convincing reasons for rejecting his testimony about the severity of his symptoms. The administrative law judge stated only that Karl M.’s statements were not entirely consistent with the medical and other evidence. Although the decision discussed medical evidence, it did not identify which of Karl M.’s statements the administrative law judge rejected or explain how particular evidence undermined those statements.

The court held that this explanation was insufficient. An administrative law judge may not reject symptom testimony solely because objective medical evidence does not fully confirm the alleged severity, and must connect the testimony being rejected to particular supporting or contradictory evidence. The Commissioner identified additional evidence and argued that Karl M. had received inconsistent treatment, but the court could review only the reasons the administrative law judge actually gave.

Disposition

The court remanded the matter for the administrative law judge to reassess Karl M.’s testimony. That reassessment could affect the residual-functional-capacity finding and the final-step finding that Karl M. could perform other work. The court therefore did not reach Karl M.’s arguments about whether the medical evidence supported the residual-functional-capacity finding or whether the vocational expert’s testimony conflicted with the Dictionary of Occupational Titles. Karl M.’s motion for summary judgment was granted in part, the Commissioner’s motion for summary judgment was denied, and the matter was remanded for proceedings consistent with the opinion.