Charles A. v. Berryhill

Background

Charles A. sought judicial review under 42 U.S.C. § 405(g) of the Acting Commissioner of Social Security’s denial of his application for disability insurance benefits. He alleged that injuries from a 2011 workplace accident—including traumatic brain injury, wrist fractures, rib fractures, pain, and mental impairments—prevented him from working.

The administrative law judge found that Charles A. had several severe impairments but retained the capacity to perform light work with restrictions. Those restrictions included avoiding unprotected heights and hazards, no more than frequent handling, fingering, or reaching, simple and routine work, limited contact with coworkers and supervisors, and few changes in the work setting. The administrative law judge found that Charles A. could not perform his past work but could perform jobs such as bench assembler, electronics worker, and cleaner. The judge therefore found him not disabled.

The parties filed cross-motions for summary judgment. Charles A.’s principal argument was that the administrative law judge failed to properly evaluate an October 2015 vocational report from Courage Kenny Rehabilitation Institute. That report concluded that Charles A. did not appear competitively employable. Charles A. also challenged the treatment of opinions from Dr. Thomas Beniak and Dr. Steven Lockman, although the court noted those issues were not directly raised in his summary-judgment motion.

Court’s Analysis

The court reviewed the administrative decision to determine whether substantial evidence supported it. Substantial evidence means enough evidence that a reasonable person could accept it as adequate, even if the record could also support another conclusion.

The court held that the administrative law judge reasonably declined to give controlling weight to the Courage Kenny report. The administrative law judge found that a key test was unreliable because Charles A. took it with his left hand even though he was right-hand dominant, and the medical records did not support the conclusion that he could not use his right hand. The administrative law judge also found that the evaluator appeared to accept Charles A.’s reported physical and mental symptoms in full, while the record as a whole did not support the full extent of those complaints.

The court identified evidence supporting those findings. Medical records described improvement in Charles A.’s wrists, including good grip, full strength, intact sensation, and only mildly reduced right-wrist motion at a later examination. Other records indicated that he used his right hand in daily activities and had been released to light-duty work. The court also noted evidence that his anger and irritability improved after a medication change, that testing showed generally strong cognitive abilities, and that he reported activities including shopping, driving, handling finances, fishing, hunting, and extensive job-search efforts.

The court further held that the administrative law judge reasonably evaluated the medical opinions. The judge gave little weight to Dr. Lockman’s opinion that Charles A. was totally disabled because the treatment records did not identify specific disabling mental limitations and the opinion was inconsistent with evidence that Charles A.’s cognitive and emotional symptoms had improved. The judge gave great weight to Dr. Beniak’s opinion that Charles A.’s cognitive abilities would not prevent him from pursuing vocational options, and the court found that decision supported by the record.

Disposition

Judge Hildy Bowbeer denied Charles A.’s Motion for Summary Judgment and granted the Acting Commissioner of Social Security’s Motion for Summary Judgment. The order directed that judgment be entered accordingly.