Parker v. Berryhill

Background

Parker sought judicial review under 42 U.S.C. § 405(g) of the Acting Commissioner of Social Security’s denial of her application for supplemental security income. The administrative law judge found that Parker had multiple severe impairments, including lupus, substance-use disorders, mental-health conditions, asthma, shoulder problems, avascular necrosis, and obesity. The judge determined that her impairments met certain disability listings when substance use was included, but that they would not meet or medically equal a listing if she stopped using substances.

The administrative law judge found that, without substance use, Parker retained the residual functional capacity—the most she could still do despite her impairments—to perform sedentary work with restrictions. Those restrictions included no exposure to certain pollutants or temperature extremes, simple and repetitive tasks, limited workplace contact, and no access to alcohol, drugs, or prescription medications other than her own. The judge found that Parker had no past relevant work but could perform jobs existing in significant numbers in the national economy, and therefore found her not disabled.

Parker raised three arguments: that the administrative law judge ignored explanations for her failure to follow prescribed treatment; that the judge selectively chose evidence when evaluating Parker’s credibility; and that testifying medical experts failed to address conflicting evidence.

Court’s Analysis

The court reviewed the administrative decision under the substantial-evidence standard. Under that standard, the Commissioner’s factual findings must be upheld if supported by substantial evidence in the record as a whole. The court explained that it could not reweigh the evidence or reverse merely because the evidence could support a different conclusion.

On treatment compliance, the court considered four explanations identified by Parker. The court concluded that the administrative law judge expressly considered three of them and addressed the fourth sufficiently in the context of the overall treatment-compliance analysis. The court acknowledged evidence that providers questioned Parker’s ability to manage her care, that medications had side effects or were sometimes ineffective, and that vomiting or hospitalizations interfered with medication or appointments. But it concluded that substantial evidence also supported the administrative law judge’s conclusion that Parker did not follow prescribed treatment.

The court also upheld the credibility analysis. The administrative law judge considered Parker’s daily activities, treatment history, medication effectiveness and side effects, medical findings, emergency-room use, mental-health evidence, and work history. The court concluded that the decision was supported by substantial evidence, including records showing normal or stable findings, reported benefits from some medications, and evidence that not every emergency-room visit was medically necessary.

The court further held that the administrative law judge did not err by assigning great weight to the opinions of Dr. Andrew Steiner and Dr. Michael Lace. The judge considered their review of the record, their specialized knowledge, and the consistency of their opinions with other evidence. The court noted that the administrative law judge—not the testifying experts—was responsible for weighing conflicting evidence, and that Parker’s counsel had questioned both experts at the hearing.

Disposition

The court concluded that none of Parker’s arguments warranted a remand to the Social Security Administration. It denied Parker’s Motion for Summary Judgment, granted the Acting Commissioner of Social Security’s Motion for Summary Judgment, and dismissed the case. The order did not state that the dismissal was with or without prejudice.