P.S. v. Kijakazi

Background

P.S. applied for disability insurance benefits and supplemental security income, alleging that she became disabled on February 28, 2020. The Social Security Administration denied the applications and denied reconsideration. After a hearing, an Administrative Law Judge (ALJ) denied the claims on October 19, 2022. The Appeals Council declined to review that decision, and P.S. appealed to the district court.

The ALJ found that P.S. had several severe impairments, including myofascial pain syndrome, right-knee osteoarthritis, cervical and lumbar degenerative disc disease, De Quervain’s tenosynovitis, somatic symptom disorder with predominant pain, and right peroneal tendonitis. The ALJ determined that these impairments did not meet or equal a listed impairment and assessed a residual functional capacity (RFC) for light work with additional limitations. The ALJ also found that jobs existed in significant numbers in the national economy that P.S. could perform.

Issue and standard of review

The court considered whether the ALJ erred by failing to find P.S. disabled under Rule 201.14 of the Social Security Medical-Vocational Guidelines, commonly called the Grids. The court could disturb the decision only if it lacked substantial evidence or applied improper legal standards. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

Court’s analysis

At the final step of the disability analysis, the ALJ considers a claimant’s RFC, age, education, and work experience to determine whether the claimant can adjust to other work. The ALJ may use the Grids and, when appropriate, testimony from a vocational expert (VE), who provides evidence about available jobs.

The court explained that the ALJ properly considered the Grids because the ALJ found both exertional limitations, which affect the ability to perform the strength requirements of work, and non-exertional limitations, such as postural and manipulative limitations. Because the ALJ assessed an RFC for light work, the ALJ considered the light-work section of the Grids. The applicable rule for light work directed a finding of no disability.

The ALJ also found that P.S.’s additional limitations impeded her ability to perform all or substantially all light work. The court concluded that Social Security Ruling 83-12 applied because P.S.’s abilities fell between the sedentary and light-work levels. Under that ruling, a slight reduction below light work supports the higher-numbered rule and a finding of no disability, while a significant reduction supports Rule 201.14 and a finding of disability. When the capacity falls in the middle, vocational-expert assistance is advisable.

The VE testified that P.S. could perform at least three specific light-work jobs while accounting for the limitations identified by the ALJ. The court held that the ALJ permissibly relied on that testimony to find no disability at the final step. Although P.S. argued that the evidence showed a significant reduction below light work, the court found that the evidence supported more than one reasonable interpretation and would not second-guess the ALJ’s choice.

The court also rejected P.S.’s arguments that the small number of job categories identified by the VE showed that her capacity was closer to sedentary work, that the available job numbers should have been reduced further, and that the identified jobs should be treated as sedentary rather than light work. The court noted that the ALJ had accounted for a fifty-percent reduction in job numbers and that the VE identified jobs P.S. could perform while standing or walking for six hours in an eight-hour workday.

Disposition

The court denied P.S.’s motion for summary judgment and granted Kijakazi’s cross-motion for summary judgment.