Armstrong v. Berryhill

Background

Mark Armstrong sought judicial review of the Acting Commissioner of Social Security’s final decision denying his application for disability insurance benefits under Title II of the Social Security Act. Armstrong alleged that osteoarthritis, spinal narrowing and disc problems, nerve and hand conditions, shoulder and knee pain, tremors, and numbness prevented him from working. He also challenged the evaluation of his anxiety, depression, and other mental-health conditions.

An administrative law judge found that Armstrong had several severe physical impairments but that his mental-health impairments were not severe. The administrative law judge determined that Armstrong could perform light work with restrictions, including no overhead tasks, no more than occasional power gripping, and no more than occasional kneeling, crawling, and crouching. The administrative law judge concluded that Armstrong could perform his past relevant work as a truck-part salesman and hospital sterilizer and therefore was not disabled. The Social Security Administration’s Appeals Council declined to review that decision.

Arguments

Armstrong argued that the administrative law judge improperly discounted the opinions of his treating physicians, Xiaoming Dong and Kurt Partoll. He also argued that the administrative law judge improperly discounted the opinions of his mental-health providers, Joseph Richmond and Lanny Law, and failed to recognize more than minimal mental-health limitations in determining his residual functional capacity, meaning the most work he could still perform despite his impairments.

The Commissioner argued that the administrative law judge’s residual-functional-capacity finding and evaluation of the medical opinions were supported by substantial evidence, meaning evidence that a reasonable person could accept as adequate to support the conclusion.

Court’s Analysis

The court held that the administrative law judge gave adequate reasons for assigning little weight to Dong’s opinion. Dong had stated that Armstrong’s symptoms would interfere with concentration, prevent even low-stress work, and cause him to miss at least four workdays per month. The court noted that Dong’s own treatment records showed normal coordination, finger movements, walking, and muscle strength in several examinations, with only mild weakness in one hand muscle. The court concluded that these records were inconsistent with Dong’s more restrictive assessment.

The court also upheld the decision to give little weight to Partoll’s opinion. Partoll had limited Armstrong to sedentary, part-time work and stated that his symptoms markedly impaired daily activities. The court relied on the administrative law judge’s findings that much of Partoll’s form was blank, Armstrong’s physical examinations were largely normal, and Armstrong reported that he could drive, shop, and manage his finances.

The court upheld the treatment of Richmond’s opinion because it was contradicted by other medical evidence, including state-agency examinations showing good mental-status examinations and no more than mild limitations in daily activities, social functioning, concentration, persistence, or pace. Although the administrative law judge did not mention Richmond’s specialty, the court found that the administrative law judge had adequately explained why Richmond’s opinion was not accepted.

The court likewise upheld the decision to give little weight to Law’s opinion. The administrative law judge found that Law’s assessment of marked or moderate limitations and inability to work was inconsistent with normal mental-status examinations and the opinions of the state-agency consultants. The court also agreed that Law, as a mental-health provider, was not qualified to offer an opinion about inability to work based partly on physical impairments and related pain.

Finally, the court concluded that the residual-functional-capacity finding was supported by medical evidence and the record as a whole. The court explained that it could not reweigh the evidence or reverse merely because other evidence might have supported a different result.

Disposition

Judge Franklin L. Noel denied Armstrong’s motion for summary judgment, granted the Commissioner’s motion for summary judgment, affirmed the Commissioner’s decision, and dismissed the case with prejudice. The order directed that judgment be entered accordingly.