Laura R. v. O'Malley

Background

Inez Laura R. sought judicial review of the Commissioner of Social Security’s final decision denying her application for disability benefits. After an earlier voluntary remand and a new administrative hearing, an administrative law judge again found that she was not disabled. The administrative law judge determined that she had severe impairments, including spondylosis, degenerative disc disease, asthma, depression, anxiety, and substance abuse. The judge assessed her as able to perform less than medium work with physical restrictions and limited her to simple, routine tasks and simple work-related decisions. Relying on vocational-expert testimony, the judge found that she could perform jobs such as table worker or inspector, final assembler, and office helper.

Medical-opinion analysis

For claims filed after March 27, 2017, Social Security regulations require the administrative law judge to evaluate the persuasiveness of all medical opinions, explicitly addressing their supportability and consistency. Supportability concerns the objective evidence and explanations supporting an opinion; consistency concerns how well the opinion fits with evidence from other medical and nonmedical sources.

The court held that the administrative law judge failed to address Dr. Jarmon’s opinion at all. Dr. Jarmon had testified that the claimant had significant cognitive loss, post-traumatic stress disorder, and schizoaffective disorder, and that her impairments met certain listed-disorder criteria in combination.

The court also held that the reasons given for discounting Dr. Cushman’s opinion were not supported by substantial evidence. Although the opinion was older, the administrative law judge did not identify medical evidence that actually contradicted Dr. Cushman’s assessment. The court found that the cited records, often involving unrelated medical visits and observations by non-mental-health providers, did not adequately undermine the limitations identified in Dr. Cushman’s psychological evaluation.

The court reached similar conclusions concerning Dr. Gonick-Hallows and Dr. Moineau. It found that Dr. Gonick-Hallows’s reports described detailed psychological testing and expressed functional limitations in terms recognized by the applicable regulations. The court rejected the administrative law judge’s characterization of the opinions as vague and found that the cited relatively normal observations did not sufficiently address the claimant’s mental-health evidence. Regarding Dr. Moineau, the court found that her report included clinical findings and observed symptoms supporting her restrictions, contrary to the administrative law judge’s statement that the report lacked objective findings. The court again found that the administrative law judge relied on treatment notes that did not meaningfully bear on the claimant’s mental health.

The court also noted that the administrative law judge would need to reconsider Merrill Featherstone’s opinion on remand. The court did not decide whether the administrative law judge properly evaluated the opinions of the state-agency psychologists because reconsideration of the other opinions could affect that analysis.

Other challenged findings

The court did not reach the claimant’s remaining arguments. It concluded that the errors in evaluating the medical opinions could have affected the step-two severity findings, the evaluation of the claimant’s statements and her daughter’s testimony, and the residual-functional-capacity assessment. Residual functional capacity is the most a claimant can still do despite her impairments.

Disposition

The court determined that further administrative proceedings were appropriate because the record did not clearly show that the claimant would necessarily be found disabled if the evidence were properly evaluated. Judge Donna M. Ryu granted the claimant’s motion for summary judgment in part, denied the Commissioner’s motion for summary judgment, and remanded the matter for proceedings consistent with the opinion.