Sheri S. v. Saul

Background

Sheri S. sought judicial review of the Commissioner of Social Security’s denial of her applications for disability insurance benefits under Title II of the Social Security Act and supplemental security income under Title XVI. An administrative law judge held a hearing and denied the applications. The administrative law judge found bipolar disorder, obesity, gout, restless leg syndrome, hypertension, asthma, carpal tunnel syndrome, and polysubstance and alcohol abuse disorder to be severe impairments.

The administrative law judge found that Sheri S.’s impairments, including substance use disorder, met the requirements of Listing 12.04, which covers certain depressive and bipolar disorders. The administrative law judge then considered what her limitations would be if she stopped using substances. In that circumstance, the administrative law judge found that she would not meet a listed impairment, would have the capacity for a limited range of light work, and could perform past work as an administrative assistant, accounting clerk, and office clerk. The administrative law judge concluded that substance use was a contributing factor material to the disability determination because Sheri S. would not be disabled if she stopped using substances.

Arguments and analysis

The parties filed cross-motions for summary judgment, asking the court to decide the case based on the administrative record. The court reviewed whether the administrative law judge’s decision was supported by substantial evidence, meaning enough relevant evidence that a reasonable person could accept it as adequate.

Sheri S. argued that the administrative law judge improperly discounted the opinion of her treating physician, Dr. Jonathan Uecker, about her functioning during periods of sobriety. Dr. Uecker’s questionnaire described marked limitations in many work-related abilities, including maintaining a routine, completing a normal workday and workweek, responding to workplace changes, and getting along with coworkers. The court upheld the administrative law judge’s decision to give that opinion little weight because Dr. Uecker’s treatment notes repeatedly described intact insight, judgment, and memory and focused attention. The court also noted that Dr. Uecker did not explain the change between those treatment notes and the more restrictive questionnaire.

The court further upheld the decision to give greater weight to opinions from state medical consultants. Although those consultants had not personally examined Sheri S., the administrative law judge explained that their opinions were supported by the record, including treatment observations and other evidence.

Sheri S. also argued that the record did not contain substantial evidence for the finding that alcohol use was a contributing factor material to her disability. The court determined that the administrative law judge reasonably relied on treatment notes showing that, when sober, Sheri S. interacted with family and a significant other, helped a neighbor, participated in hobbies, maintained logical thought processes and intact memory, focused her attention, followed her medication regimen, and cared for herself. The court acknowledged that some evidence supported Sheri S.’s position, including evidence of continuing anxiety and difficulty sleeping and concentrating, but explained that the administrative law judge did not have to find her symptom-free. The court concluded that the administrative law judge’s findings were supported by substantial evidence.

Ruling

Judge Tony N. Leung denied Plaintiff’s Motion for Summary Judgment, granted Defendant’s Motion for Summary Judgment, and dismissed the matter. The opinion states that judgment was to be entered accordingly.