Mann v. Kijakazi

Background

Alicia Mann sought judicial review of the Commissioner of Social Security’s denial of her disability-benefits application. An Administrative Law Judge (ALJ) found that Mann had central retinal arterial occlusion with right-eye vision loss and an adjustment disorder with depressed mood. The ALJ determined that these impairments were severe but did not meet or equal a listed impairment.

The ALJ assessed Mann’s residual functional capacity (RFC), meaning the most she could still do despite her limitations. The RFC allowed a full range of work at all exertional levels, with limits including only occasional need for depth perception, frequent rather than constant stooping or bending, simple and routine tasks, and work in a low-stress environment. The ALJ found that Mann could not return to her past relevant work but, based on vocational-expert testimony, could perform work as a marker, marker II, or ticket taker. The ALJ therefore found her not disabled, and the Appeals Council denied review.

Issues and Analysis

Mann argued that the ALJ improperly discounted part of Dr. Patricia Spivey’s psychological opinion, particularly the opinion that Mann had a marked impairment in withstanding the stress of a routine workday. The court explained that newer Social Security regulations focus on the supportability and consistency of medical opinions rather than giving opinions presumptive weight based on the doctor’s relationship with the claimant. The court held that the ALJ reasonably found Dr. Spivey’s opinion unpersuasive to the extent it suggested limitations beyond the RFC because Dr. Spivey’s examination findings did not support the marked stress limitation and provided no explanation for it.

Mann also challenged the ALJ’s assessment of her testimony about her symptoms and limitations. The court concluded that the ALJ properly considered the medical evidence, Mann’s reported activities, and her continued work, including part-time work. The court found that substantial evidence supported the RFC and that the ALJ gave adequate reasons for not accepting the full degree of limitation alleged by Mann.

The court rejected Mann’s argument that the RFC did not sufficiently address her right-eye vision loss. Mann did not identify an additional limitation supported by the evidence, and the court found no basis to conclude that the jobs identified by the vocational expert required near vision in both eyes. The court also rejected Mann’s challenge concerning a function report from her adult son, Byron Thomas, explaining that the governing regulations did not require the ALJ to separately describe how evidence from nonmedical sources was considered and that the report did not support a different result.

Disposition

Chief United States District Judge Richard Seeborg denied Mann’s motion for summary judgment and granted the Commissioner’s motion for summary judgment. The court upheld the ruling that Mann had failed to establish disability.