Erin F. v. Berryhill

Background

Erin F. sought judicial review under 42 U.S.C. § 405(g) of the Acting Commissioner of Social Security’s final decision denying her application for supplemental security income. She alleged that schizoaffective disorder and ankylosing spondylitis prevented her from working. The administrative law judge found severe impairments including degenerative disc disease, schizoaffective disorder, and attention-deficit/hyperactivity disorder, but found that none met or equaled a listed impairment.

The administrative law judge determined that Erin F. retained the capacity to perform less than the full range of light work, with limits on lifting, sitting, standing, walking, postural activities, mental tasks, workplace changes, and interactions with coworkers, supervisors, and the public. Because she had no past relevant work, the administrative law judge relied on vocational testimony that she could perform jobs such as small-products assembler, sub-assembler, or electrical-accessories assembler. The administrative law judge therefore found her not disabled, and the Appeals Council denied review.

Issues and Analysis

Erin F. challenged the evaluation of several categories of evidence. She argued that the administrative law judge improperly gave little weight to a March 2015 opinion from her treating psychiatrist, Dr. Steven Grandt. Dr. Grandt’s check-box opinion described extreme or marked limitations in attention, concentration, following schedules, working with others, responding to criticism and workplace changes, tolerating stress, and performing other work-related activities. He also opined that Erin F. would miss work more than three days per month and need additional breaks.

The court agreed that the administrative law judge properly found the opinion inconsistent with Dr. Grandt’s treatment notes, mental-status examinations, and Erin F.’s reported activities. The records described her as pleasant and cooperative, with intact attention, concentration, cognition, and memory at various visits. They also indicated that Haldol helped control hallucinations and Adderall helped control attention-deficit/hyperactivity disorder symptoms when taken. The court further found that activities such as caring for a pet, reading, writing, doing household tasks, attending movies, shopping, playing musical instruments, taking extended vacations, helping care for her spouse, and earning two college degrees were inconsistent with the extreme limitations in Dr. Grandt’s opinion. The court also noted that the check-box form contained little explanation or supporting medical evidence and therefore had little evidentiary value.

The court rejected Erin F.’s argument that the administrative law judge failed to consider the relationship between her physical pain and psychological symptoms. The administrative law judge considered her pain complaints but found that the claimed severity and effects were inconsistent with the physical activity documented in the record and that the pain improved with medication and injections. The court also found that the cited records contained only Erin F.’s subjective reports of pain.

The court rejected the argument that the administrative law judge improperly relied on personal medical judgments. It explained that assessing residual functional capacity—the most a person can do despite medical limitations—is the administrative law judge’s responsibility based on all the medical and other evidence, including resolving conflicts among medical opinions.

Finally, the court rejected Erin F.’s challenge to the weight given to non-examining state-agency psychological consultants. The court found that the reconsideration-level consultant’s records review was broader than Erin F. assumed and that the consultants’ conclusions were consistent with the medical evidence, treatment notes, mental-status examinations, daily activities, and medication effectiveness. The court also found that the recommendation for an adult rehabilitative mental health services worker did not require a different result, particularly because the record did not show that Erin F. had applied for or been approved for those services.

Ruling

The court reviewed the Commissioner’s decision under the substantial-evidence standard, which asks whether enough evidence supports the decision that a reasonable person could accept it. The court held that the administrative law judge did not commit the alleged errors and that substantial evidence supported the denial of benefits.

The order denied Erin F.’s Motion for Summary Judgment and granted Commissioner Nancy A. Berryhill’s Motion for Summary Judgment. The court directed that judgment be entered accordingly.