C.L. v. O'Malley

Background

C.L. asked the court to review the Social Security Administration’s final decision denying her claims for disability insurance benefits and supplemental security income. The Administrative Law Judge found that C.L. had severe impairments including lupus, obesity, an unspecified mood disorder, generalized anxiety disorder, and post-traumatic stress disorder. The judge found interstitial cystitis and abnormal uterine bleeding non-severe, and found that fibromyalgia was not a medically determinable impairment. The judge concluded that C.L. could not perform her past work but could perform other jobs, and therefore was not disabled.

C.L. moved for summary judgment, asking the court to reverse and remand the decision. The Commissioner filed a cross-motion for summary judgment. C.L. argued that the Administrative Law Judge had improperly evaluated her interstitial cystitis, abnormal uterine bleeding, and fibromyalgia; medical opinions; symptom testimony; and statements from her sister and Social Security claims representatives.

Analysis

The court held that the Administrative Law Judge erred in evaluating some of C.L.’s impairments at step two of the disability analysis. Step two is a screening stage that asks whether an impairment significantly limits basic work activities. The court found that the judge failed to consider the combined effects of C.L.’s illnesses, gave insufficient consideration to her interstitial-cystitis symptoms, and failed to consider her descriptions of urinary problems. The court also found that C.L. had provided enough evidence, given the low burden at step two, to show that her fibromyalgia could qualify as a medically determinable impairment under the applicable Social Security ruling. The errors were not harmless because they affected the judge’s assessment of C.L.’s ability to work.

The court partially remanded on the medical-opinion issue. It found that the reasons given for discounting treating psychiatrist Dr. Abishek Reddy’s opinion were supported by substantial evidence. It also found that the Administrative Law Judge adequately explained why state-agency psychologist Dr. Elizabeth Covey’s opinion was persuasive. Because the step-two analysis was erroneous, however, the judge could reconsider the opinions of Dr. J. Linder and Dr. G. Dale on remand.

The court also found that the Administrative Law Judge’s reasons for discounting C.L.’s symptom testimony were not clear and convincing. Because the case was already being remanded, the judge could reconsider that testimony. In contrast, the court found no error in the treatment of statements from C.L.’s sister and observations by Social Security claims representatives G. Martinez and D. Tran.

Disposition

Judge Beeler granted C.L.’s motion for summary judgment in part, denied the Commissioner’s cross-motion for summary judgment, and remanded the case for further proceedings consistent with the order. The court did not award benefits in the order.