McArdell v. Saul

Background

Patricia McArdell sought judicial review of the Social Security Administration’s denial of her application for disability insurance benefits and supplemental security income for the period from March 6, 2013, through March 5, 2018. She alleged disability based on multiple mental and physical disorders.

An administrative law judge initially found that McArdell was not disabled. The Social Security Administration Appeals Council vacated that decision and sent the case to a new administrative law judge. The new administrative law judge again denied the claim, and the Appeals Council again vacated the decision and sent it back for further consideration. After a third hearing, the administrative law judge denied benefits for the period before March 6, 2018, but found that McArdell became disabled on March 6, 2018, because she had entered an older age category and there were no longer jobs existing in significant numbers in the national economy that she could perform. The Appeals Council denied review, making that decision final.

Both sides moved for summary judgment. Magistrate Judge Hildy Bowbeer recommended granting the Commissioner’s motion and denying McArdell’s motion. McArdell objected.

Court’s analysis

The district court conducted a fresh review of the portions of the recommendation to which McArdell objected and reviewed the administrative law judge’s decision for substantial evidence. Substantial evidence means enough evidence that a reasonable person could find it adequate to support the decision. The court explained that it could not reweigh the evidence or replace the administrative law judge’s judgment with its own.

McArdell argued that the administrative law judge improperly assessed her residual functional capacity, meaning what she could still do in a work setting despite her limitations. She contended that the assessment did not include restrictions specifically addressing each of her mental disorders and related symptoms. The court rejected that argument, finding that the administrative law judge addressed the impairments in the record and reasonably determined that McArdell could perform light work with exceptions and simple, routine tasks.

The court also rejected McArdell’s arguments concerning her reactions to stress, including seizures, lost time, shaking hands, lack of behavioral control, poor memory, flashbacks, and incontinence. It found that the administrative law judge addressed those symptoms and that the restriction to simple, routine tasks accounted for the described deficits. The court likewise found that the decision addressed McArdell’s mild limitation in interacting with others and her moderate limitations in concentration, persistence, and pace.

Disposition

The court overruled McArdell’s objection and adopted the report and recommendation in its entirety. It denied McArdell’s motion for summary judgment, granted Andrew Saul’s motion for summary judgment, and dismissed the case with prejudice.