Trae B. v. Commissioner of Social Secuity

Background

Trae B. sought judicial review of an administrative law judge’s decision denying an application for disability benefits under Title II and Title XVI of the Social Security Act. The application alleged disability beginning May 1, 2016. After an earlier administrative decision was remanded by the Appeals Council, a second administrative hearing was held and the administrative law judge again found that Trae B. was not disabled.

The administrative law judge found severe impairments including irritable bowel syndrome, visceral hypersensitivity syndrome, depression, anxiety, marijuana and alcohol use, degenerative disc disease, and erythrocytosis. The judge found that Trae B. had the residual functional capacity—the most a person can still do despite medical limitations—to perform light work with restrictions. Those restrictions included no climbing of ladders, ropes, or scaffolds; only occasional stooping and crouching; avoiding concentrated exposure to hazards; performing simple, routine tasks; and having only occasional interaction with coworkers and the public. Because Trae B. had no past relevant work, the administrative law judge relied on a vocational expert’s testimony that Trae B. could perform work as a sub-assembler, inspector, or cleaner.

Claims

Trae B. raised two claims. First, Trae B. argued that the administrative law judge failed to follow the Appeals Council’s instructions to address the effects of gastrointestinal and mental-health impairments, explain the evidence supporting each part of the residual functional capacity, discuss the treatment history, and adequately explain the mental residual functional capacity. Trae B. also argued that the residual functional capacity was not supported by sufficient evidence because the administrative law judge ignored or mischaracterized favorable evidence.

Second, Trae B. argued that the administrative law judge improperly rejected testimony about the intensity and limiting effects of pain and other symptoms. Trae B. argued that the reasons given for discounting that testimony were not specific, clear, and convincing.

Court’s analysis

The court held that the administrative law judge sufficiently complied with the Appeals Council’s instructions and supported the residual functional capacity with substantial evidence. The court explained that the administrative law judge was required to discuss the medical evidence, but was not required to accept all of it. The court also concluded that Trae B.’s disagreement with the evaluation of the evidence amounted to a request to reweigh the evidence, which the court would not do where the administrative findings were supported by substantial evidence.

Regarding the mental limitations, the court rejected Trae B.’s argument that the administrative law judge had to include every moderate limitation marked in the first section of the mental residual functional capacity forms completed by Dr. Dennis and Dr. Colsky. The court explained that the forms stated that the first section was not the actual mental residual functional capacity assessment. The doctors’ concrete limitations, recorded in the narrative and additional-explanation sections, limited Trae B. to simple, unskilled work with limited public and social contact. The court found that the administrative law judge’s residual functional capacity accounted for those limitations.

The court also held that the administrative law judge gave specific, clear, and convincing reasons for discounting Trae B.’s symptom testimony. The reasons included objective medical findings, gaps in treatment, improvement with treatment and psychiatric care, inconsistencies in statements about medical visits, weight loss, work history, drug use, and other matters, and daily activities such as caring for a cat, preparing meals, grocery shopping, and interacting with others. The court concluded that the administrative law judge did not err in rejecting the testimony.

Disposition

The court denied Trae B.’s Motion for Summary Judgment and granted the Commissioner’s Motion for Summary Judgment.