Martin v. Saul

Background

Dawn Martin applied for disability insurance benefits under Title II of the Social Security Act in May 2017. She alleged that she became unable to work on May 28, 2013. She identified fibromyalgia, back and neck injuries, anxiety, depression, a foot injury, swelling in both hands, and migraines as conditions limiting her ability to work.

The Social Security Administration denied the application and denied it again on reconsideration. After a hearing, an administrative law judge found that Martin was not disabled from May 28, 2013, through her date last insured, December 31, 2016. The judge found that Martin had severe degenerative disc disease in her cervical, thoracic, and lumbar spine, but determined that she could perform a reduced range of sedentary work. The judge found that she could not return to her past work but could perform jobs such as order clerk for food and beverages, leaf tier for tobacco leaves, or telephone solicitor. The Appeals Council denied review, making the administrative law judge’s decision final.

Court’s Analysis

The court reviewed the agency’s decision to determine whether it was supported by substantial evidence—relevant evidence that a reasonable person could accept as sufficient—or was based on legal error.

The court upheld the administrative law judge’s Step Two findings. It concluded that substantial evidence supported the finding that Martin’s mental impairments caused no more than mild limitations and therefore were not severe impairments. The court also upheld the finding that the record did not establish fibromyalgia as a medically determinable impairment under the applicable diagnostic criteria. The court further found that failing to separately address Ehlers-Danlos syndrome was not improper because the later diagnosis lacked sufficient supporting evidence for the relevant period and the administrative law judge had incorporated Martin’s symptoms into the residual functional capacity assessment. Any possible Step Two error was harmless because the administrative law judge found a severe impairment and continued through the remaining steps.

The court also upheld the administrative law judge’s treatment of certain opinions from treating physician Michael Moskowitz. The judge reasonably found those opinions unpersuasive because they were vague, unsupported by the overall record, and inconsistent with Moskowitz’s contemporaneous treatment notes. The court noted that the newer Social Security regulations require an administrative law judge to address the supportability and consistency of medical opinions rather than automatically favoring a treating physician’s opinion.

The court reached a different conclusion regarding Martin’s testimony about her symptoms. The administrative law judge stated that Martin’s statements about the intensity, persistence, and limiting effects of her symptoms were not entirely consistent with the evidence, then summarized the medical evidence. The court held that this did not identify which specific testimony was rejected or connect that testimony to particular evidence. Because Martin testified that she needed to lie down up to ten times a day, and a vocational expert testified that such a limitation would prevent sustained employment, the court could not find the error harmless.

Disposition

The court granted Martin’s motion for summary judgment and denied the defendant’s motion for summary judgment. It remanded the case to the Social Security Administration for further proceedings consistent with the order, limited to the inadequate evaluation of Martin’s subjective symptom testimony. The court directed the clerk to enter judgment in Martin’s favor and close the case. Judge Haywood S. Gilliam, Jr. issued the order. The order remanded the case for further proceedings; it did not itself award disability benefits.