M.N. v. Kijakazi

Background

M.N. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner’s final decision denying her applications for disability insurance benefits and supplemental security income. She alleged that she became disabled on October 18, 2018, because of adhesive capsulitis of the right shoulder, depression, anxiety with panic attacks, and insomnia. The administrative law judge found that M.N. had not engaged in substantial gainful activity, had severe shoulder and mental impairments, and did not meet a listed impairment.

The administrative law judge determined that M.N. had the residual functional capacity—the most she could still do despite her impairments—to perform medium work with mental restrictions. Those restrictions allowed only occasional contact with coworkers and supervisors, no shared tasks with coworkers, and brief, tangential contact with the public. Although the judge found that M.N. could not perform her past relevant work, the judge found, based on vocational-expert testimony, that she could perform jobs such as hand packer or stores laborer. The judge therefore found that she was not disabled. The Appeals Council denied review.

Issues and Analysis

M.N.’s summary-judgment motion focused on her mental impairments. She argued that the administrative law judge improperly evaluated her credibility, improperly assessed several medical opinions, and failed to properly evaluate third-party statements from a former supervisor and former coworker.

Evaluation of M.N.’s testimony

The court held that the administrative law judge gave sufficiently clear and convincing reasons, supported by substantial evidence, for partially crediting M.N.’s testimony. The judge accepted that M.N.’s anxiety and panic attacks were triggered mainly by social interactions and performing before others. The judge accounted for those symptoms by imposing significant limits on contact with coworkers, supervisors, and the public.

The court concluded that the judge reasonably found that M.N.’s symptoms were not completely debilitating. The record showed that M.N.’s relationship with a roommate and other shelter residents improved, that she managed some stress related to the COVID-19 pandemic, attended part-time online college classes, grocery-shopped without assistance, and traveled internationally by plane. The court acknowledged that these activities did not necessarily show that M.N. could work, but found that they weighed against her claim of a totally debilitating impairment. The court also noted that the judge recognized fluctuations in M.N.’s symptoms and adjusted the restrictions to reduce social stressors.

Medical opinions

The court found substantial evidence supporting the administrative law judge’s evaluation of the medical opinions under the regulations applicable to claims filed after March 27, 2017. Those regulations require consideration of factors including supportability and consistency and do not give automatic preference to treating physicians.

The court upheld the treatment of Dr. Chandler’s examining opinion, which described mild-to-moderate impairment in interacting with the public, supervisors, and coworkers. The court found that Dr. Chandler’s opinion was based on a clinical interview, mental-status examination, and behavioral observations, and was consistent with opinions from the nonexamining consultants, Drs. McClain and Colsky. The court also found that comments from treating physicians Dr. Painter and Dr. Fisher did not clearly state that M.N.’s condition was completely disabling, particularly when social stressors could be reduced.

The court further upheld the evaluation of Ms. Smith’s opinion that M.N. could not maintain stable employment. It found that Ms. Smith’s treatment notes largely reflected improvement during much of the relevant period and that her written opinion emphasized difficulty interacting or responding to others. The court concluded that this limitation was consistent with, and addressed by, the restrictions in M.N.’s residual functional capacity. The court also noted that Ms. Smith did not address whether M.N. could work if particular social triggers were removed or reduced.

Third-party statements

M.N. argued that the administrative law judge improperly discounted statements from Ms. Fick, a former supervisor, and Mr. Evans, a former coworker. The court did not decide whether the Social Security Administration’s newer regulations changed the prior requirement that an administrative law judge give specific reasons for rejecting lay testimony. Instead, it held that the judge did not reject the statements. The judge expressly considered both letters and imposed restrictions on M.N.’s interactions with supervisors, coworkers, and the public. The court found that the letters did not show that M.N. could not work under those restrictions.

Disposition

Judge Edward Chen concluded that the administrative law judge did not commit clear error and that the findings were supported by substantial evidence. The court denied M.N.’s motion for summary judgment and granted the Social Security Administration’s cross-motion for summary judgment. The order disposed of Docket Nos. 11 and 12, directed entry of final judgment, and directed the Clerk to close the case.