D.F. v. Kijakazi
- Laurel Beeler
- 3:23-cv-01106
- U.S. District Court · Northern District of California
- 8
In D.F. v. Kijakazi, Judge Beeler denied D.F.’s summary-judgment motion and affirmed the denial of disability benefits.
D.F.’s claim for Social Security benefits remains denied, and the Commissioner’s decision was affirmed.
What happened
In D.F. v. Kijakazi, D.F. asked the court to review the Social Security Administration’s decision denying benefits. An administrative law judge found that D.F. had schizophrenia and cannabis use disorder but could perform certain work, and the agency’s Appeals Council upheld that decision.
D.F. argued that the administrative law judge wrongly rejected borderline intellectual functioning as a medically established impairment, improperly discounted D.F.’s testimony, and failed to properly address statements from D.F.’s mother.
Judge Beeler denied D.F.’s motion for summary judgment, granted the Commissioner’s cross-motion for summary judgment, and affirmed the agency’s decision. The court found one error concerning borderline intellectual functioning but held that it did not affect the outcome.
The detailed version
- D.F. v. Kijakazi · No. 3:23-cv-01106
- Laurel Beeler
- Apr. 1, 2024
Background
D.F. sought judicial review of the Commissioner of Social Security’s final decision denying benefits. The opinion says that D.F. filed an application for supplemental security income on November 24, 2020, alleging disability beginning January 1, 2020. The introduction instead describes the claim as one for disability insurance benefits under Title II of the Social Security Act.
The administrative law judge (ALJ) denied the claim initially and on reconsideration. After a telephone hearing at which D.F. and a vocational expert testified, the ALJ determined that D.F. was not disabled. The ALJ found severe impairments of schizophrenia and cannabis use disorder, but found that D.F. could perform work at all exertional levels with limitations to simple routine tasks, simple workplace decisions, occasional interaction with supervisors and coworkers, brief and superficial interaction with the public, and a workplace with little change and routine. The ALJ concluded that jobs existed in significant numbers in the national economy that D.F. could perform. The Appeals Council denied review, making the ALJ’s decision final.
Issues
D.F. moved for summary judgment, arguing that the ALJ:
- Wrongly determined that borderline intellectual functioning was not a medically determinable impairment;
- Improperly discounted D.F.’s symptom testimony; and
- Improperly rejected statements from D.F.’s mother.
Court’s Analysis
Borderline intellectual functioning
At the second step of the disability analysis, an ALJ decides whether a claimant has a severe impairment. The court explained that this is a low-threshold screening step. The ALJ had found insufficient clinical, diagnostic, and laboratory evidence to establish borderline intellectual functioning as a medically determinable impairment, despite a consultative examination that diagnosed the impairment based on psychometric testing showing a full-scale intelligence quotient of 74.
The court held that the ALJ’s conclusion was error, particularly because D.F.’s burden at this stage was low. But the court found the error harmless because the ALJ considered the functional limitations discussed by the doctor who conducted the testing when determining D.F.’s residual functional capacity (RFC), meaning the most work the claimant can still perform despite impairments. The ALJ accounted for those limitations by restricting D.F. to simple routine tasks and simple workplace decisions. The court therefore denied summary judgment on this ground.
D.F.’s testimony
D.F. argued that the ALJ failed to give sufficiently clear reasons for rejecting D.F.’s testimony about symptoms. The court held that the ALJ gave specific, clear, and convincing reasons, including that D.F.’s schizophrenia was well managed with medication and that mental-status examinations showed no particular deficits. The court denied remand on this ground.
Statements from D.F.’s mother
D.F. argued that the ALJ had to address D.F.’s mother’s statements and provide specific reasons for discounting them. The court explained that regulations effective in 2017 did not require an ALJ to explain how the ALJ considered evidence from nonmedical sources, including family members. The court therefore held that the ALJ was not required to provide specific reasons for rejecting the mother’s testimony.
Disposition
The court denied D.F.’s motion for summary judgment, granted the Commissioner’s cross-motion for summary judgment, and affirmed the ALJ’s decision. The order resolved ECF Nos. 11 and 15.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.