Mary G. v. Berryhill

Background

Mary G. challenged the Commissioner of the Social Security Administration’s denial of her application for disability benefits. She alleged that she became unable to work on June 30, 2014. Her medical history included fibromyalgia, pain in her arms, neck, and hands, trigger thumb, breast cancer treated with chemotherapy, surgery, and radiation, and occasional anxiety and depression. Her breast cancer was in remission.

An administrative law judge (ALJ), Roger Thomas, found that Mary G. had several severe physical impairments but that her anxiety and depression caused no more than mild limitations in certain areas of mental functioning. The ALJ determined that she could perform light work with restrictions, including limits on climbing, bending, kneeling, crawling, overhead tasks, exposure to extreme temperatures, wet conditions, vibrations, and workplace hazards. The ALJ found that she could return to her past relevant work as a cost accountant and therefore was not disabled under the Social Security Act. The Social Security Appeals Council declined review, making the ALJ’s decision the Commissioner’s final decision.

Issues and Analysis

Mary G. raised four main arguments.

First, she argued that the ALJ should have included additional restrictions for her cervical disc disease, carpal tunnel syndrome, and trigger thumb. The court rejected the argument that an impairment found severe at the early screening stage must automatically produce a matching restriction in the residual functional capacity (RFC), meaning the most work a person can do despite medical limitations. The court found that the medical evidence supported the ALJ’s decision not to impose additional hand or arm restrictions. The court noted that her trigger-thumb surgery was largely successful, later examinations showed normal strength and sensation, and her carpal tunnel syndrome was described as doing okay. The ALJ also reasonably relied on a consultant’s opinion that did not identify hand-manipulation limitations.

Second, Mary G. argued that the ALJ should have classified her past work as a price analyst rather than a cost accountant. The court found no error because the vocational expert considered Mary G.’s description of her prior work and testified that cost accountant was the better classification. The court concluded that substantial evidence supported the ALJ’s classification.

Third, Mary G. argued that the ALJ should have included work restrictions addressing the mild limitations identified in social functioning and concentration, persistence, and pace. The court concluded that the record supported the ALJ’s finding that her anxiety and depression were not severe impairments and caused no more than a minimal effect on basic work activities. The court also found that the cases Mary G. cited did not require RFC restrictions based only on mild limitations where the record lacked significant mental-health treatment or other supporting evidence.

Fourth, Mary G. argued that the ALJ should have considered whether she qualified for a closed period of disability during and after her cancer treatment. The court explained that a closed period requires disabling limitations lasting at least twelve months. The ALJ identified a period of roughly nine or ten months when her fatigue and pain were worse during chemotherapy and radiation, which did not satisfy that requirement. The court also found substantial evidence supporting the ALJ’s conclusion that her condition improved and that later examinations did not establish disability.

Ruling

The court concluded that the ALJ’s decision was supported by substantial evidence and did not result from legal error. Judge Menendez denied Mary G.’s motion for summary judgment, granted the Commissioner’s motion for summary judgment, and dismissed the matter with prejudice. The court ordered judgment to be entered accordingly.