D. v. Kijakazi

Background

Labryssa appealed the Commissioner of Social Security’s final decision denying her application for supplemental security income under Title XVI of the Social Security Act. She alleged disability based on bipolar disorder, generalized anxiety disorder, posttraumatic stress disorder, cyclical vomiting, asthma, and gender dysphoria. After a hearing, the administrative law judge found that she was not disabled. The Appeals Council affirmed that decision.

The administrative law judge found four severe mental impairments but treated cyclical vomiting and asthma as non-severe. The judge determined that Labryssa had the residual functional capacity—the most she could still do despite her impairments—to perform work at all physical exertion levels, subject to limits such as simple, routine tasks and only occasional interaction with others. Relying on vocational-expert testimony, the judge found that Labryssa could work as a hand packager, routing clerk, or housekeeper.

Labryssa’s Challenges

Labryssa argued that the administrative law judge improperly discounted her testimony about the severity of her symptoms, rejected the opinion of psychological consultative examiner Dr. Laura Jean Catlin, failed to classify cyclical vomiting and asthma as severe impairments, and improperly assessed her residual functional capacity. The Commissioner argued that substantial evidence supported the administrative law judge’s findings.

The court upheld the administrative law judge’s reasons for partially discounting Labryssa’s testimony. It found that the judge identified inconsistencies between some of Labryssa’s statements and the medical records and cited evidence that medication and treatment had improved some symptoms. The court emphasized that the judge had not rejected all of Labryssa’s testimony, but had discounted only some statements about the severity of her symptoms.

The court held, however, that the administrative law judge did not adequately evaluate Dr. Catlin’s opinion. Under the newer Social Security regulations, the most important factors in evaluating medical opinions are supportability and consistency. The court found that the administrative law judge addressed those factors only in general terms, did not meaningfully engage with Dr. Catlin’s examination and testing, and did not adequately explain why the opinion’s marked limitations were unsupported or inconsistent with the record.

The court also found no prejudicial error in the step-two classification of cyclical vomiting and asthma because the administrative law judge continued through the remaining steps of the disability analysis. But the court held that those conditions still had to be considered when assessing the residual functional capacity, even if they were not severe impairments. The court concluded that the step-five finding that Labryssa could work was therefore not supported by substantial evidence.

Disposition

Judge Beth Labson Freeman determined that further administrative proceedings, rather than an immediate award of benefits, were appropriate. The record needed further consideration of the medical evidence, Dr. Catlin’s opinion, and all of Labryssa’s impairments when formulating an appropriate residual functional capacity. The court therefore granted in part and denied in part Labryssa’s motion for summary judgment, denied the Commissioner’s motion for summary judgment, reversed the denial of benefits, and remanded the matter to the Commissioner for further administrative proceedings.