Inta P. v. Saul
- Paul Magnuson
- 0:19-cv-01714
- U.S. District Court · District of Minnesota
- 5
In Inta P. v. Saul, Judge Magnuson denied Inta P.’s summary-judgment motion and granted the Commissioner’s.
Inta P., whose application for disability insurance benefits remained denied, and the Commissioner of Social Security, whose decision was supported by the court.
What happened
Inta P. v. Saul concerned Inta P.’s application for disability insurance benefits. She alleged disability beginning April 1, 2016, based on a kidney transplant, memory problems, fatigue, and other physical complaints. An administrative law judge found several severe impairments but concluded that she was not disabled because she could perform work available in significant numbers.
Inta P. argued that the judge’s assessment of her work capacity failed to account for likely absences, frequent breaks, and all of her impairments. The court rejected those arguments because she had not provided medical evidence supporting the claimed future absences or break needs. It also found no support for considering a digestive-disorder listing because she had not been diagnosed with a digestive disorder and her cited digestive problems did not support the listing.
The court concluded that substantial evidence supported the denial of benefits. Judge Magnuson denied Inta P.’s motion for summary judgment and granted the Commissioner’s motion for summary judgment.
The detailed version
- Inta P. v. Saul · No. 0:19-cv-01714
- Paul Magnuson
- Feb. 10, 2020
Background
Inta P. applied for disability insurance benefits in April and May 2016. She alleged that she had been unable to work since April 1, 2016, because of a kidney transplant, memory problems, fatigue, and other physical complaints.
After a hearing, an administrative law judge (ALJ) found severe impairments including chronic kidney disease following a transplant, left carpal tunnel syndrome, migraines, and an organic mental disorder. The ALJ found that none of the impairments met or medically equaled a listed impairment. The ALJ also found that Inta P. had the residual functional capacity (RFC)—the ability to perform work despite her limitations—to perform routine, repetitive, unskilled tasks with routine workplace stress, subject to her physical limitations. The ALJ therefore found that she was not disabled. The Appeals Council affirmed that decision.
Issues and Analysis
The court reviewed the Commissioner’s decision to determine whether substantial evidence supported it. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support the decision.
Inta P. argued that the RFC did not account for absences caused by infections related to medication following her kidney transplant. The court noted that one of the four hospitalizations she identified was for a tonsillectomy unrelated to the transplant. More importantly, the court found that she had not provided medical evidence showing that her past infections or work absences established that she would have future infections or absences. The court also noted that she had worked part-time since the alleged onset date and had a current job requiring skills beyond the RFC assessed by the ALJ.
Inta P. also argued that she would need frequent restroom and other breaks. The court rejected this argument because she had not provided medical evidence since the alleged onset date supporting that limitation.
Finally, Inta P. argued that the ALJ should have considered Listing 5.08, which concerns weight loss caused by a digestive disorder. The court found no record support for that listing because Inta P. had not been diagnosed with a digestive disorder and had not identified a provider who made such a diagnosis. The court noted that diverticulitis in 2016 had resolved, that no later digestive problems were cited, and that another digestive issue she identified occurred before the alleged onset date. The court also noted that the ALJ had found diverticulitis was not a severe impairment.
Disposition
The court held that substantial evidence supported the Commissioner’s decision to deny benefits. Judge Paul A. Magnuson ordered that Inta P.’s Motion for Summary Judgment was DENIED and the Commissioner’s Motion for Summary Judgment was GRANTED.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.