C.C. v. Kijakazi

Background

C.C. challenged the Commissioner of Social Security’s final decision finding her not disabled and denying her disability benefits and Supplemental Security Income benefits. C.C. alleged disability beginning November 24, 2018, based on impairments including degenerative disc disease, myalgia, right-shoulder rotator cuff syndrome, and extreme obesity. During the relevant period, her recorded weight ranged from 380 to 409 pounds.

The administrative law judge found obesity and C.C.’s other listed conditions to be severe impairments. At the third step of the disability analysis, the judge found that no impairment, alone or combined with another impairment, met the requirements of a listed impairment. The judge stated that obesity had been considered under Social Security Ruling 19-2p, but did not otherwise explain obesity’s effects in the decision.

The judge found that C.C. had the residual functional capacity—the most she could still do despite her impairments—to perform light work with restrictions, including limits on certain movements, occasional overhead reaching with her right arm, and the ability to alternate between sitting and standing as needed. The judge found that C.C. could not perform her past work as a home attendant but could perform other work available in the national economy. The Appeals Council denied review, making the administrative law judge’s decision the Commissioner’s final decision.

Parties’ Arguments

C.C. argued that the administrative law judge failed to explain how obesity affected her residual functional capacity, as required by Social Security Ruling 19-2p and relevant Ninth Circuit authority. She pointed to medical evidence that weight loss would help her back pain, as well as opinions from PA Brooke Aber and Dr. Steven Kao that imposed greater restrictions than the judge’s residual-functional-capacity finding.

The Commissioner argued that the administrative law judge had acknowledged obesity as a severe impairment and reasonably found that it caused no additional limitations beyond those already included in the residual functional capacity. The Commissioner also argued that the court could not substitute its judgment for the administrative law judge’s judgment.

Court’s Analysis

The court explained that it could affirm, modify, or reverse the Commissioner’s decision, with or without sending the matter back for another hearing. The court had to uphold the decision unless it contained legal error or lacked substantial evidence—relevant evidence that a reasonable person could accept as adequate to support the conclusion. The court could review only the reasons the administrative law judge actually gave.

The court held that the administrative law judge did not sufficiently address C.C.’s obesity. The record showed that obesity could affect C.C.’s back impairment: a treating physician assistant stated that weight loss would likely reduce her back pain, and the record repeatedly described C.C. as morbidly obese. The court also noted that C.C.’s weight at times exceeded 400 pounds and that the record listed a body mass index as high as 60.4.

Under Social Security Ruling 19-2p, the agency must consider obesity’s limiting effects when determining residual functional capacity and must explain how it reached its conclusion about whether obesity causes limitations. The court found that the administrative law judge did not explain how obesity affected C.C.’s ability to sit, stand, walk, or sustain work over time, or how it affected her other impairments.

The court rejected the Commissioner’s assertion that the record contained no opinions imposing greater restrictions. It identified greater restrictions in opinions from PA Aber and Dr. Kao. The court also stated that C.C.’s obesity could support her testimony that she could not sit, stand, or walk for long periods without lying down to recover.

The court acknowledged that the record was mixed. Some reports described normal gait and strength, while others described pain, reduced range of motion, an antalgic gait, difficulty getting off an examination table, and shoulder abnormalities. The court stated that resolving this mixed evidence was the administrative law judge’s role, but the judge had to explain the reasoning and consider all relevant impairments. Because the decision lacked reviewable findings about obesity’s effects, the court did not decide whether the record could otherwise support the administrative law judge’s conclusions.

Disposition

The court granted C.C.’s motion for summary judgment, denied the Commissioner’s cross-motion, and remanded the matter to the Commissioner for further administrative proceedings consistent with the order. On remand, the Commissioner was directed to address specifically how C.C.’s obesity affected or might alter the conclusion that her limitations were less severe than those assessed by Dr. Kao, PA Aber, and C.C.’s testimony. The Clerk was directed to enter judgment in favor of C.C. and close the case.