Jacqlyn S. v. Kijakazi

Background

JACQLYN S. sought disability benefits based on physical and mental impairments, including major depressive disorder, post-traumatic stress disorder, anxiety disorder, chronic fatigue syndrome, postural orthostatic tachycardia, obstructive sleep apnea, migraine headaches, short-term memory deficit, and Lyme disease. She alleged disability beginning July 1, 2011. After an earlier administrative decision was remanded by the Appeals Council, a different administrative law judge found that she was disabled beginning October 1, 2015, but not before that date. Because her insured status ended on March 31, 2014, the earlier onset date was important to her claim.

JACQLYN S. sought judicial review under 42 U.S.C. § 405(g). Both sides filed motions for summary judgment, which ask the court to decide whether the administrative decision should stand based on the record.

Court’s analysis

The court first addressed JACQLYN S.’s argument under Social Security Ruling 18-1p. It found that she had not identified a specific legal error concerning that ruling, so it considered her other arguments about the onset date.

Medical opinions

The court held that the administrative law judge did not give sufficiently specific and legitimate reasons for discounting Dr. Steven Harris’s opinion about JACQLYN S.’s limitations before October 2015. The administrative law judge said Dr. Harris’s treatment notes did not support his opinion and that his opinion conflicted with the broader medical record. But, according to the court, the administrative law judge did not adequately explain which findings contradicted which limitations or why the cited treatment recommendations were considered conservative. The court also noted that Dr. Harris relied on laboratory findings and symptoms that he believed were consistent with chronic Lyme disease and that the record did not show obvious inconsistencies between his treatment notes and his opinion.

The court also found that the administrative law judge did not fully satisfy the required standard when discounting portions of Dr. Charles Fenzi’s opinion concerning limitations before October 2015. The administrative law judge relied in part on JACQLYN S.’s ability to maintain a driver’s license and travel independently. The court found that this reasoning failed to account for the difficulties she experienced during those activities, including limited driving time, fatigue, and difficulty interacting with others during a 2014 trip.

JACQLYN S.’s symptom testimony

The administrative law judge found that JACQLYN S.’s impairments could reasonably be expected to produce her alleged symptoms, and the court therefore required specific, clear, and convincing reasons to reject her testimony about the severity of those symptoms. The court found that none of the three reasons given met that standard.

First, the administrative law judge did not adequately identify which medical findings contradicted JACQLYN S.’s specific testimony. The court also found that the administrative law judge relied on selected periods of improvement while overlooking evidence of worsening symptoms and the opinions of Dr. Harris and Dr. Fenzi.

Second, the administrative law judge relied on limited and conservative treatment before October 2015 without addressing JACQLYN S.’s explanations. Those explanations included the cost of intravenous antibiotic treatment, side effects from mental-health medications, lack of insurance, and difficulty attending appointments because of her health.

Third, the court found that JACQLYN S.’s daily activities—including attending school part-time, driving, shopping, living with a roommate, and doing household tasks—did not provide a sufficient basis for rejecting her testimony. The record also showed that she needed rest, assistance, accommodations, or breaks, and eventually stopped attending classes because she felt too sick.

Disposition

Judge Jacquelyn Corley concluded that the errors concerning the medical evidence and JACQLYN S.’s symptom testimony were not harmless because they went to the center of the disability determination. The court did not need to decide the additional argument concerning lay-witness testimony.

The court declined to order payment of benefits because the record was not fully developed and it was unclear whether proper evaluation of the evidence would require a finding that JACQLYN S. was disabled before October 2015. The court therefore granted JACQLYN S.’s motion for summary judgment, denied the Commissioner’s cross-motion, and remanded for further proceedings consistent with the order.