C.B. v. Kijakazi

Background

C.B. challenged the Commissioner of Social Security’s final decision denying her application for disability insurance benefits under Title II of the Social Security Act. C.B. has chronic fatigue syndrome, fibromyalgia, cognitive dysfunction, anxiety disorder, post-traumatic stress disorder, and depression. After a hearing, the administrative law judge found that C.B. could not perform her past relevant work but retained the residual functional capacity—the most she could still do despite her impairments—to perform sedentary, unskilled work. Based on vocational-expert testimony, the administrative law judge identified jobs such as lens gauger, addresser, and circuit board assembler. The Appeals Council denied review, making the administrative law judge’s decision the Commissioner’s final decision.

Court’s Analysis

The court held that the administrative law judge failed to give legally sufficient reasons for rejecting C.B.’s testimony about the severity of her symptoms. Because the administrative law judge found that C.B.’s impairments could reasonably cause the alleged symptoms and made no finding of malingering, the administrative law judge needed specific, clear, and convincing reasons supported by substantial evidence. The court found that C.B.’s household activities were sporadic and involved substantial rest, that the pacemaker procedure did not discredit symptoms attributed to chronic fatigue syndrome and fibromyalgia, and that brief mental-status findings did not contradict her broader mental-health and cognitive complaints. The court also found that the administrative law judge selectively relied on portions of neuropsychological evaluations while overlooking conclusions that C.B.’s fatigue-related cognitive deficits interfered with daily functioning.

The court further held that the administrative law judge improperly evaluated medical opinions from Drs. Christopher R. Snell, Hector Bonilla, Harris, and Sugden. The administrative law judge did not adequately explain the opinions’ supportability and consistency, as required by the applicable regulations. In particular, the administrative law judge mischaracterized Dr. Snell’s two-day cardiopulmonary exercise test report, failed to address relevant portions of his opinion, and relied on normal cardiac testing without explaining why it was inconsistent with the chronic-fatigue-syndrome evidence. The administrative law judge also did not identify specific evidence contradicting Dr. Bonilla’s, Dr. Harris’s, or Dr. Sugden’s findings. The court additionally found that the administrative law judge did not provide a specific, germane reason—a reason tied to the witness—for discounting testimony from C.B.’s partner, Beth.

Because the administrative law judge’s residual functional capacity assessment may have omitted limitations supported by the medical opinions, the court found that the vocational expert’s testimony about available sedentary work might have been based on an incomplete hypothetical. The court therefore found remand appropriate for a new step-five determination after proper evaluation of the medical evidence. The court also determined that the Appeals Council had considered Dr. Snell’s September 2020 letter, incorporated it into the administrative record, and considered it in reviewing the Commissioner’s decision; the court concluded that the letter did not change its analysis because the relevant points were already addressed in other evidence.

Disposition

The court GRANTED Plaintiff’s Motion for Summary Judgment, DENIED Defendant’s Cross-Motion for Summary Judgment, and REMANDED the matter for further proceedings consistent with the order. The opinion also states that the court previously denied C.B.’s motion to supplement the record without prejudice because it was not filed as a separate motion and lacked a proposed order and proper supporting declaration.