Normalya T. v. Kijakazi

Background

Normalya T. sought judicial review of the Social Security Administration Commissioner’s denial of her application for benefits. She alleged that she became unable to work after a violent attack on July 20, 2015. The administrative law judge found that she had several severe impairments, including bilateral de Quervain’s tenosynovitis, asthma, migraine with aura, anxiety with panic attacks, post-traumatic stress disorder, major depressive disorder, and panic disorder. The administrative law judge determined that she could perform limited light work and identified jobs existing in significant numbers in the national economy.

Court’s analysis

The court held that the administrative law judge improperly rejected Normalya T.’s statements about the severity and effects of her symptoms. The administrative law judge described her function report as showing that she regularly prepared meals, performed household chores, used public transportation, shopped, and handled her finances. But the report instead stated that she avoided public transportation and crowds, rarely prepared meals, usually ate at the shelter, and generally left home only for appointments. The court also found that the administrative law judge ignored evidence that panic attacks and anxiety made it difficult for Normalya T. to use public transportation, shop, retrieve mail, obtain diapers, and complete housing paperwork independently. The court further held that the administrative law judge did not show that these activities occupied a substantial part of her day or transferred to a work setting.

The court also found errors in the evaluation of medical opinions. The administrative law judge referred to two state-agency psychological consultants but discussed the supportability and consistency of only one opinion, leaving unclear which opinion had been analyzed. The court found that the administrative law judge selectively cited medical records and disregarded records showing anxiety, panic attacks, depression, and other symptoms. The court therefore rejected the reasons given for discounting the testimony of medical expert David Jarmon, PhD, and the report of Laura Catlin, PsyD. The court also held that the administrative law judge improperly assessed the severity of Normalya T.’s mental-health conditions at the third step of the disability analysis and improperly assessed the limitations from her wrist condition when determining her residual functional capacity, meaning the most she could do despite her impairments.

Remedy and disposition

The court concluded that the record was sufficiently developed to decide whether Normalya T. met a listed impairment and that the administrative law judge had not given legally sufficient reasons for rejecting her statements and the medical opinions. The court found that the evidence established, at minimum, that she met Listing 12.15 for trauma- and stressor-related disorders because of her post-traumatic stress disorder. It found the required trauma-related symptoms, at least marked limitations in interacting with others and adapting or managing herself, and the required persistence and treatment history. Because the court found no serious doubt that she was disabled under the Social Security Act, it ordered remand for an immediate calculation and payment of benefits. Judge Jon S. Tigar granted Plaintiff’s motion for summary judgment and denied the Commissioner’s cross-motion for summary judgment.