Muniz v. Kijakazi

Background

Tina M. Muniz sought review under 42 U.S.C. § 405(g) of the Social Security Administration Commissioner’s partially favorable disability decision. The administrative law judge found Muniz disabled beginning December 11, 2020, but found that she was not disabled before that date. Muniz asked the court to find her disabled and award benefits for September 16, 2017, through December 10, 2020. The Commissioner asked the court to affirm the agency’s decision.

The administrative law judge found that Muniz had several severe impairments, including fibromyalgia, osteoarthritis, carpal tunnel syndrome, degenerative disc disease, diabetes, asthma, depression, and anxiety. The judge found that Muniz could perform a restricted range of sedentary work, including simple work without a production pace such as assembly-line work. Before December 11, 2020, the judge found that Muniz could perform three occupations identified by a vocational expert: lens gauger, addressor, and table worker. Beginning December 11, 2020, a change in Muniz’s age category led the judge to find that no jobs existed in significant numbers that she could perform.

Court’s analysis

The court held that the administrative law judge did not properly account for Muniz’s mental limitations in the residual functional capacity assessment. A residual functional capacity assessment describes the most work a person can do despite physical and mental limitations. The administrative law judge found persuasive the opinion of psychologist Janine Marinos, who stated that Muniz could understand, remember, and carry out simple instructions and interact appropriately with others, but might have moderate difficulty maintaining concentration and coping with usual workplace stress.

The court found that the administrative law judge appeared to adopt those limitations but did not explain how they were reflected in the residual functional capacity. The court concluded that limiting Muniz to simple work without a production pace did not necessarily address her individualized ability to concentrate and cope with work stress. The administrative law judge therefore needed to make specific findings about those limitations and how they affected Muniz’s ability to work.

The court also found that this error was not harmless. The administrative law judge had asked the vocational expert about a person who would be off task for 15 percent of the workday, and the vocational expert testified that such a person would essentially be unemployable. The court did not decide that Muniz necessarily had to be found disabled, however, because the record did not explain whether the administrative law judge believed Muniz’s moderate limitations actually meant she would be off task 15 percent of the day.

The court rejected Muniz’s other challenges. It held that the administrative law judge properly considered the overall evidence when evaluating Muniz’s depression and anxiety and did not rely only on the absence of psychiatric hospitalization or crisis holds. The court also held that the mental-status examinations and an IQ score could be considered along with the other medical evidence. In addition, the court found that the administrative law judge gave sufficiently specific reasons, supported by substantial evidence, for finding that Muniz’s testimony about the intensity and effects of her physical and mental symptoms was not fully supported by the record. Finally, the court concluded that the administrative law judge properly considered Muniz’s fibromyalgia and chronic pain syndrome.

Disposition

The court granted in part and denied in part Muniz’s motion for summary judgment. It granted the motion to the extent Muniz requested a remand for further administrative proceedings and denied her request for an immediate award of benefits. The court denied the Commissioner’s cross-motion for summary judgment, reversed the Commissioner’s final decision, and remanded the case under 42 U.S.C. § 405(g) for further proceedings consistent with the order.

Judge Edward J. Davila determined that additional administrative proceedings were useful because unresolved questions remained about how the administrative law judge would translate Muniz’s concentration and work-stress limitations into workplace restrictions and whether those restrictions would affect the disability determination.