Kassandra A. J. v. Saul

Background

Kassandra A. J. is a child under 18. Her mother brought the case on Kassandra’s behalf after the Social Security Administration denied Kassandra’s application for supplemental security income benefits. The application alleged disability beginning in October 2011 based on autism spectrum disorder, hypothyroidism, mycoplasma pneumoniae, a blood disorder, and neurological conditions causing low functioning in her upper extremities.

An administrative law judge found that Kassandra had several severe impairments: asthma, sensory integration or sensory processing disorder, developmental delay, chronic pain syndrome, depression, and anxiety. The judge found hypothyroidism and mycoplasma pneumoniae non-severe and concluded that the medical records did not demonstrate the claimed blood disorder, neurological conditions, or autism spectrum disorder. The judge determined that none of Kassandra’s severe impairments met, medically equaled, or functionally equaled a listed impairment, and therefore found her not disabled. The Appeals Council affirmed that decision.

Kassandra’s Argument

Kassandra argued that the administrative law judge improperly concluded that the medical records did not support an autism spectrum disorder diagnosis, despite the opinion of the Commissioner’s independent medical expert. She argued that autism spectrum disorder was a severe impairment and asked the court either to award benefits or to send the case back to the administrative law judge for fuller consideration of the medical evidence.

Court’s Analysis

The court reviewed the Commissioner’s decision under the substantial-evidence standard. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion. The court explained that it could not reweigh conflicting evidence; if the record could support two different conclusions and one was the administrative law judge’s conclusion, the court had to uphold that decision.

The court determined that the administrative law judge properly considered the conflicting evidence about autism spectrum disorder. Clinicians at Fraser diagnosed Kassandra with the disorder in September 2018, but teachers, school administrators, a neuropsychologist, and Kassandra’s treating psychiatrist disagreed with that conclusion. The administrative law judge also considered differences in Kassandra’s behavior when she was alone compared with when her parents were present. Although the neuropsychological evaluation was not autism-specific, it examined several functions relevant to an autism diagnosis, including nonverbal cues, eye contact, social functioning, and attention.

The court concluded that the record contained more than substantial evidence supporting the administrative law judge’s finding that the medical evidence did not substantiate autism spectrum disorder as a severe impairment. The court also found no error in the administrative law judge’s analysis of whether Kassandra’s impairments functionally equaled the listed impairments. The administrative law judge had reviewed the medical records and determined that Kassandra did not have marked limitations, and that determination was supported by substantial evidence.

Disposition

Judge Paul A. Magnuson ordered that Kassandra’s motion for summary judgment was DENIED and the Commissioner’s motion for summary judgment was GRANTED. The court directed that judgment be entered accordingly.