Marie H. v. Saul
- Katherine Menendez
- 0:18-cv-03486
- U.S. District Court · District of Minnesota
- 3
In Tina Marie H. v. Saul, Judge Menendez denied Tina Marie H.’s motion and granted Saul’s, upholding the disability decision.
Tina Marie H. and the Commissioner of Social Security; the ruling upheld the finding that Tina Marie H. was no longer disabled by migraine headaches after December 16, 2016.
What happened
In Tina Marie H. v. Saul, Tina Marie H. challenged an administrative law judge’s finding that she was no longer disabled by migraine headaches after December 16, 2016. She had previously received a partly favorable determination.
The court found substantial evidence that her headaches had improved with medication, nerve blocks, and Botox treatments. Her headaches became less frequent and shorter, were nearly or completely relieved by medication, and she continued working as a water aerobics instructor.
The court ruled that the administrative law judge’s decision was supported by the evidence. Judge Menendez denied Tina Marie H.’s motion for summary judgment and granted the Commissioner’s motion for summary judgment.
The detailed version
- Marie H. v. Saul · No. 0:18-cv-03486
- Katherine Menendez
- Feb. 19, 2020
Background
Tina Marie H. received a partially favorable determination on June 7, 2018. She challenged the administrative law judge’s finding that, after December 16, 2016, she was no longer disabled by migraine headaches. Both sides moved for summary judgment, asking the court to rule based on the administrative record.
Court’s analysis
The court reviewed the administrative law judge’s decision to determine whether it followed the law and was supported by substantial evidence. “Substantial evidence” means relevant evidence that a reasonable person would consider adequate to support the decision.
The court found substantial evidence of medical improvement. Earlier records showed headaches occurring up to 20 days per month, with poor control from medication and little response to treatments such as Imitrex or Maxalt. In 2017, after a new drug, nerve blocks, and Botox treatments, the records described stable symptoms: one or two headaches per week lasting minutes to hours, with symptoms completely or nearly completely resolved by Maxalt.
The court also found substantial evidence supporting removal of a restriction that had anticipated at least two absences per month after December 16, 2016. The record showed improvement in the headaches’ frequency, duration, and intensity, and indicated that Tina Marie H. could perform normal activities and work despite her migraines. She continued working at the YMCA as a water aerobics instructor.
The court further determined that the administrative law judge appropriately considered Tina Marie H.’s reported symptoms alongside the medical records and her work history. Although the administrative law judge did not discuss the work history in detail in the written decision, he had discussed it with her during the hearing. The court concluded that her statement that she could not work with her migraines was not entirely consistent with the record after December 16, 2016.
Ruling
The court concluded that the administrative law judge’s determination was supported by substantial evidence and that summary judgment for the Commissioner was appropriate. Judge Katherine Menendez ordered that Tina Marie H.’s motion for summary judgment was DENIED and the Commissioner’s motion for summary judgment was GRANTED.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.