T.D. v. Kijakazi

Background

The plaintiff sought judicial review of the Commissioner of Social Security’s final decision denying her application for Social Security disability insurance benefits under Title II of the Social Security Act. She applied on October 16, 2020. After the claim was denied initially and on reconsideration, an administrative law judge (ALJ) held a hearing on November 3, 2021. The ALJ issued an unfavorable decision on November 19, 2021, and the Appeals Council denied review on October 27, 2022, making the ALJ’s decision final.

The ALJ found that the plaintiff had severe impairments consisting of fibromyalgia, systemic lupus erythematosus, and interstitial lung disease. The ALJ determined that she had the residual functional capacity (RFC)—her ability to work despite her impairments—to perform light work with restrictions on climbing, certain postures, exposure to temperature extremes and pulmonary irritants, vibration, and workplace hazards. The ALJ found that she could perform past work as an administrative clerk, purchasing agent, and exhibit display representative.

Arguments

The plaintiff challenged four aspects of the ALJ’s decision: the finding that her Raynaud syndrome was not severe; the finding that her lupus did not meet or equal a listed impairment; the treatment of statements from treating physicians Vincenzo Vitto, D.O., and Michael Chu, D.O., who issued work-status reports; and the consideration of medication side effects in the RFC assessment.

Court’s Analysis

The court reviewed the Commissioner’s decision under 42 U.S.C. § 405(g). It could set aside the decision only if the ALJ committed legal error or relied on findings unsupported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate support for the conclusion.

On Raynaud syndrome, the court held that the ALJ sufficiently established that the condition had only a minimal effect on the plaintiff’s ability to work. The court pointed to evidence that the condition was managed with treatment and that objective testing showed full grip and motor strength. The court denied remand on this ground.

On lupus, the court held that the ALJ’s finding was supported by evidence that the plaintiff’s lupus was stable and not active during the relevant period, as well as by testimony from state agency consultants. The court deferred to the ALJ’s decision because the record supported different possible outcomes and denied remand on this ground.

Regarding the treating physicians’ work-status reports, the court explained that the ultimate question of whether a claimant can work is for the Commissioner to decide, not for a treating physician to resolve. The court denied remand on this ground as well.

Finally, the court held that substantial evidence supported the ALJ’s RFC assessment despite the plaintiff’s claim that medication side effects were not adequately considered. The court noted that the cited side effects from Amitriptyline and Prozac were temporary, and that records stated the plaintiff was not taking Prozac even though it had been prescribed. The court denied remand on this ground.

Disposition

Judge Laurel Beeler denied the plaintiff’s motion for summary judgment and granted the Commissioner’s cross-motion for summary judgment. The court denied the plaintiff’s request for a remand and resolved ECF Nos. 16 and 18.