Jacqueline R. M. v. Saul
- Paul Magnuson
- 0:19-cv-02586
- U.S. District Court · District of Minnesota
- 6
In Jacqueline R. M. v. Saul, Judge Magnuson denied her summary-judgment motion and granted the Commissioner’s, leaving the disability-benefits denial in place.
The ruling affects Jacqueline R. M.’s applications for disability insurance benefits and supplemental security income benefits; the Commissioner’s denial of those benefits remains in place.
What happened
In Jacqueline R. M. v. Saul, Jacqueline R. M. challenged the Social Security Commissioner’s decision denying her disability insurance and supplemental security income benefits. She alleged physical and mental impairments, including chronic pain, fibromyalgia, depression, anxiety, and mobility problems.
She argued that the Administrative Law Judge’s finding about her ability to work was not supported by enough evidence and that the judge improperly evaluated medical opinions. The Administrative Law Judge found that she could not return to her past child-care work but could perform sedentary work with restrictions and could perform other jobs existing in significant numbers.
Judge Magnuson ruled that substantial evidence supported the Commissioner’s decision. The court denied Jacqueline R. M.’s motion for summary judgment and granted Andrew M. Saul’s motion for summary judgment.
The detailed version
- Jacqueline R. M. v. Saul · No. 0:19-cv-02586
- Paul Magnuson
- Apr. 10, 2020
Background
Jacqueline R. M. applied for disability insurance benefits and supplemental security income benefits in 2016. She alleged that she had been disabled since May 31, 2016, because of physical conditions including pudendal neuropathy, back, neck, and shoulder pain and limited mobility, fibromyalgia, and chronic pain syndrome. She also alleged major depressive disorder, anxiety disorder, and somatic symptom disorder.
After a hearing, the Administrative Law Judge (ALJ) found several severe impairments, including shoulder impingement and degenerative joint disease, cervical and lumbar degenerative disc disease after lumbar surgery, chronic pain syndrome, fibromyalgia, myofascial pain syndrome, bilateral carpal tunnel syndrome, pudendal neuropathy, depression, generalized anxiety disorder, and somatic symptom disorder. The ALJ found that none of these impairments met or medically equaled a listed impairment.
The ALJ determined that Jacqueline R. M. had the residual functional capacity (RFC)—the most she could still do despite her impairments—to perform sedentary work with restrictions. The ALJ found that she could not return to her past work as a child-care provider but could perform other work existing in significant numbers in the national economy. The ALJ therefore found that she was not disabled, and the Appeals Council affirmed that decision.
Arguments and analysis
Jacqueline R. M. brought this action under 42 U.S.C. § 405(g). She argued that substantial evidence did not support the RFC determination and that the ALJ should have given more weight to certain medical opinions. She asked the court either to award benefits or to remand the case to the ALJ for further consideration of the medical evidence.
The court’s review was limited to whether the Commissioner’s decision was supported by substantial evidence in the record as a whole. The court concluded that the ALJ thoroughly discussed the relevant medical evidence and gave specific reasons for the weight assigned to the medical opinions. The court also noted that, under the regulations applicable to the application, physician assistant Matthew Hawkins and physical therapist Nathan Ryan were not acceptable medical sources.
The court further concluded that the ALJ properly discounted opinions stating that Jacqueline R. M. could not work because those opinions relied almost entirely on her subjective complaints and symptom reports rather than testing or other objective findings. The court cited evidence that, despite one physician’s opinion that she was totally disabled, examinations showed a normal gait and functional strength.
Ruling
Judge Paul A. Magnuson concluded that substantial evidence supported the Commissioner’s decision to deny benefits. The court ordered that Jacqueline R. M.’s Motion for Summary Judgment was DENIED and Andrew M. Saul’s Motion for Summary Judgment was GRANTED, and directed that judgment be entered accordingly.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.