Molly M. v. Saul

Background

Molly M. sought judicial review under the Social Security Act of an administrative law judge’s decision denying her applications for benefits under Titles II and XVI. The administrative law judge found that she had not engaged in substantial gainful activity since her alleged onset date, and found severe impairments including posttraumatic stress disorder, chronic fatigue syndrome, depressive disorder, and anxiety disorder. The administrative law judge did not evaluate panic disorder, chronic severe insomnia, environmental sensitivities, or nervous exhaustion at the required stage or otherwise account for their limitations.

The administrative law judge determined that Molly M. could perform work at all exertional levels, subject to limits involving routine work and limited interaction with the public, coworkers, and supervisors. The administrative law judge found that she could perform her past work as a tutor and music teacher and could also perform other jobs, including touch-up screener, document preparer, and final assembler. The administrative law judge therefore found her not disabled since October 1, 2017.

Both parties moved for summary judgment, which asks the court to decide the case based on the administrative record and governing law. Molly M. requested a remand for further proceedings. The court also addressed whether the record required a remand for an immediate award of benefits, even though neither party had requested that specific relief.

Court’s analysis

The court held that the administrative law judge clearly erred by failing to account for several impairments and by failing to develop the record regarding their limitations. The court also found that the administrative law judge improperly rejected opinions from James Goetz, Psy.D., and Anna O’Malley, M.D. The administrative law judge had described Dr. Goetz’s opinion as inadequately supported and inconsistent with some normal mental findings, and had rejected Dr. O’Malley’s opinion as inadequately explained and because she did not appear to be a psychiatry specialist. The court found those reasons unsupported by substantial evidence.

The court considered the opinions of Drs. Goetz and O’Malley, the opinion of Glenn Francis, Psy.D., reports from Molly M. and her friend, and the extensive treatment records. It concluded that this evidence consistently showed marked limitations in understanding and memory, concentration and persistence, interacting with others, and adapting to surroundings. The court therefore treated the improperly rejected medical opinions as true under the applicable rule.

The court concluded that the requirements for an immediate award of benefits were met: the administrative law judge had failed to provide legally sufficient reasons for rejecting the evidence; no outstanding issues required resolution; and the record showed that the administrative law judge would be required to find Molly M. disabled if the evidence were credited. The court determined that her impairments met or equaled the criteria for listed depressive, posttraumatic-stress, and anxiety-related disorders. It also concluded that the combined impairments left her without the residual functional capacity to function in the workplace. In addition, the vocational expert testified that a person with Molly M.’s education and background would not be employable if she consistently missed as little as 90 minutes of work each day, and the court found that the record showed limitations at least that severe.

Disposition

Judge Robert M. Illman granted Molly M.’s motion for summary judgment and denied the defendant’s cross-motion. The court also denied the defendant’s request to strike Molly M.’s motion. It reversed the administrative law judge’s finding of non-disability and remanded the case for the immediate calculation and award of appropriate benefits consistent with the opinion.