Jodi L. W. v. Saul

Background

Jodi L. W. sought judicial review of the Commissioner of Social Security’s denial of her application for Supplemental Security Income under Title XVI of the Social Security Act. She alleged impairments including traumatic brain injury, mental-health conditions, depression, hepatitis C, anxiety, attention-deficit disorder, neck surgery, right-side weakness, and memory loss.

An Administrative Law Judge (ALJ) denied the claim on May 30, 2019, and the Appeals Council denied review. The ALJ found severe impairments including major depressive disorder, attention-deficit hyperactivity disorder, generalized anxiety disorder, posttraumatic stress disorder, degenerative disc disease of the cervical spine, and ulnar neuropathy. The ALJ determined that Jodi had the residual functional capacity (RFC)—the most she could still do despite her impairments—to perform light work with restrictions. Although the ALJ found that she could not perform her past work, he concluded that she could perform other jobs existing in significant numbers in the national economy.

The parties filed cross-motions for summary judgment, asking the court to decide the case based on the administrative record.

Court’s Analysis

The court reviewed whether the ALJ’s decision was supported by substantial evidence and was free of legal error. The court focused on the ALJ’s treatment of medical opinions and the resulting RFC assessment.

The ALJ gave little weight to the opinions of Jodi’s examining and treating mental-health providers, state-agency medical and psychological consultants, and the State of Minnesota’s disability determination. The ALJ described those opinions as “not entirely consistent” with the medical record or with other providers’ notes. The court held that this wording was too imprecise to show what the ALJ meant or whether the opinions were mostly, partially, or materially inconsistent with the record. Because the ALJ gave little weight to all of the opinions, the court could not determine whether he had properly considered the medical opinions and the related medical evidence.

The court also concluded that the ALJ had rejected every medical opinion offered by examining or consulting providers and was therefore left without medical-provider opinions supporting the RFC. Although an ALJ is responsible for assessing RFC based on all relevant evidence, the court stated that an RFC is a medical question and must be supported by some medical evidence. The court determined that the ALJ’s conclusions were not supported by substantial evidence.

Disposition

The court granted Jodi L. W.’s motion for summary judgment and denied the Commissioner’s motion for summary judgment. It vacated the Commissioner’s decision as to steps four through five and remanded the case under Sentence Four of 42 U.S.C. § 405(g) for further proceedings consistent with the opinion.