Street v. Kijakazi

Background

Charlene J. Street sought judicial review under 42 U.S.C. § 405(g) of the final decision denying her Social Security Disability Insurance benefits. The administrative law judge found that Street had not engaged in substantial gainful activity, had several severe impairments—including bipolar disorder, anxiety disorder, personality disorder, cannabis use disorder, alcohol use disorder, and psoriasis—and did not have an impairment meeting or equaling a listed impairment.

The administrative law judge assessed Street’s residual functional capacity, meaning the work she could still perform despite her impairments. Considering all of her impairments, including her substance-use disorders, the judge found that Street could not perform her past work or other jobs existing in significant numbers in the national economy. The judge therefore initially found her disabled. The judge then evaluated whether drug addiction or alcoholism, referred to in the opinion as “DAA,” was material to that finding. Without the substance-use disorders, the judge found that Street would not have significant monthly absences and could perform her past work as a broker clerk or administrative assistant. The judge consequently concluded that Street was not disabled under the Act because her substance use was a material contributing factor.

Street’s Arguments

Street argued that the record did not support the finding that her substance-use disorders were material. She pointed to her reported periods of abstinence and argued that she remained unable to perform her former work or other jobs. She also argued that the administrative law judge improperly evaluated her statements, her spouse’s statements, and her daily activities when assessing her work-related limitations.

Street separately challenged the administrative law judge’s use of vocational-expert testimony. The vocational expert testified that a person with the limitations attributed to Street, including missing work about three days each month, could not perform any work. Street argued that this testimony and the medical evidence better reflected her limitations.

Court’s Analysis

The court reviewed the administrative decision to determine whether it was supported by substantial evidence—relevant evidence that a reasonable person could consider adequate—or based on legal error. The court could not consider new evidence or substitute its judgment for the Commissioner’s when the record reasonably supported more than one conclusion.

The court held that substantial evidence supported the finding that Street had ongoing alcohol and cannabis use disorders and that those disorders materially contributed to the disability finding. The court relied on evidence that Street continued using cannabis, that alcohol relapses were associated with serious symptoms, and that her functioning and reported symptoms improved during periods without substance use. The court also noted evidence that Street’s symptoms and work performance improved when she was sober.

The court also upheld the administrative law judge’s evaluation of Street’s statements about her inability to work. It found that the judge reasonably considered generally benign mental-status examinations, Street’s daily activities, her ability to drive significant distances to care for a family member, and evidence that she had been laid off because her employer was experiencing financial problems rather than because of her medical conditions.

Finally, the court held that the administrative law judge properly considered the vocational expert’s testimony both with and without the substance-use disorders. The testimony that no work was available for a person who would miss work three days per month supported the initial disability finding, but the judge also properly determined that Street could perform her past work without the substance-use disorders.

Disposition

The court found that the administrative law judge’s decision was supported by substantial evidence. It DENIED Street’s Motion for Summary Judgment, GRANTED the Commissioner’s Motion for Summary Judgment, and AFFIRMED the Commissioner’s final decision. Judgment was entered in favor of the Commissioner, and the clerk was directed to close the file.