Denise W. v. Berryhill
- Steven Rau
- 0:17-cv-04592
- U.S. District Court · District of Minnesota
- 26
In Denise W. v. Berryhill, Judge Rau denied Denise W.’s motion for summary judgment, granted the Commissioner’s motion, and dismissed the case.
Denise W. did not obtain disability insurance benefits or supplemental security income through this case; the Commissioner’s denial was left in place, and the matter was dismissed.
What happened
Denise W. v. Berryhill concerned Denise W.’s challenge to the denial of her applications for disability insurance benefits and supplemental security income. She said depression, anxiety, attention-deficit/hyperactivity disorder, arthritis, and hearing loss prevented her from working. An administrative law judge found that she was not disabled and could perform her past work.
Denise W. argued that the administrative law judge gave too little weight to opinions from psychiatrist Thomas Kefalas and therapist Cindy Lee Thomas. The court concluded that those opinions described limitations that were inconsistent with treatment records, generally normal mental-status examinations, improvement with medication, limited therapy, testing, and Denise W.’s part-time work and other activities.
The court ruled that the administrative law judge properly evaluated the medical opinions and that the decision was supported by substantial evidence. Judge Steven E. Rau denied Denise W.’s summary-judgment motion, granted the Commissioner’s summary-judgment motion, and dismissed the matter.
The detailed version
- Denise W. v. Berryhill · No. 0:17-cv-04592
- Steven Rau
- Dec. 7, 2018
Background
Denise W. sought judicial review of the Social Security Administration’s denial of her applications for disability insurance benefits under Title II and supplemental security income under Title XVI. She alleged that she became disabled on August 15, 2007, because of major depressive disorder, anxiety, attention-deficit/hyperactivity disorder, degenerative arthritis, and hearing loss.
The administrative law judge (ALJ) found severe impairments including obesity, osteoarthritis, trochanteric bursitis, major depressive disorder, and anxiety disorder. The ALJ determined that Denise W. did not have an impairment meeting or equaling a listed impairment and had the residual functional capacity to perform less than a full range of medium work, with limits on lifting, social interaction, and contact with others. The ALJ found that she could perform her past work and was not disabled from August 15, 2007, through the date of the decision. The Social Security Appeals Council denied review.
Arguments and Analysis
Denise W. argued that the ALJ improperly weighed opinions from psychiatrist Dr. Thomas Kefalas and therapist Cindy Lee Thomas. Dr. Kefalas described serious limitations involving concentration, instructions, attendance, stress, work pace, and the need for breaks and absences. Thomas also described marked limitations in many work-related mental activities and opined that Denise W. would have more than three absences per month.
The court held that the ALJ had sufficient reasons for giving those opinions less weight. The treatment records, including Dr. Kefalas’s own treatment notes, generally showed normal mental-status findings and improvement or stability with medication. The court also relied on Denise W.’s part-time work as a bingo caller, assistance with a wax-worm business, computer use, television watching, and other reported activities. The court noted that Thomas was not an acceptable medical source under the applicable regulations and that Denise W.’s therapy sessions were infrequent. It further observed that psychological testing showed only moderate inattention during complicated tasks, normal frustration tolerance, no notable hyperactivity, and an ability to understand directions.
The court rejected Denise W.’s argument that her work history supported her disability claim. It concluded that the record showed she had worked for substantial periods despite reporting that her mental-health conditions had existed for many years. Overall, the court found that the medical record did not support the severe limitations described by Dr. Kefalas and Thomas.
Ruling
Applying deferential review under the Social Security Act, the court determined that the ALJ’s evaluation of the medical opinions was not legally erroneous and was supported by substantial evidence in the record as a whole. Judge Steven E. Rau denied Plaintiff’s Motion for Summary Judgment, granted Defendant’s Motion for Summary Judgment, and ordered that the matter be dismissed. The order did not state whether the dismissal was with or without prejudice.
Read the full 26-page opinion on CourtListener, the free public archive maintained by the Free Law Project.