A.S.A. v. Saul

Background

A.S.A., representing himself, sought judicial review of the Commissioner of Social Security’s final decision denying his application for Supplemental Security Income. He alleged disability based on bipolar disorder and schizoaffective disorder. An administrative law judge held a hearing on April 18, 2019, and issued an unfavorable decision on June 4, 2019. The Appeals Council denied review on December 2, 2019, making the administrative law judge’s decision the Commissioner’s final decision.

The administrative law judge applied the required five-step disability evaluation. The judge found that A.S.A. had several severe mental impairments but did not have an impairment meeting or equaling a listed impairment. The judge assigned a residual functional capacity—the most a person can still do despite physical or mental limitations—that allowed a full range of work at all exertional levels, subject to limits. A.S.A. could understand, remember, and perform simple, repetitive instructions; make simple work-related decisions; have only brief and superficial contact with coworkers and supervisors; have no contact with the public; and deal with only infrequent changes in a routine work setting.

The administrative law judge found that A.S.A. had no past relevant work but could perform work as a night cleaner, industrial cleaner, or carton feeder. The judge therefore found him not disabled from July 17, 2017, the application date, through June 4, 2019, the date of the decision.

Arguments and Evidence

The court understood A.S.A.’s complaint to argue that the administrative law judge failed to account properly for his mental diagnoses and limitations. A.S.A. testified that anxiety, depression, mental outbursts, difficulty understanding instructions, and conflicts with supervisors prevented him from working. He also submitted a function report stating that he had difficulty with stress and crowds, while reporting that he could follow written and spoken instructions somewhat well and communicate adequately with authority figures.

The administrative law judge relied substantially on opinions from state-agency psychologists Michael E. Cremerius and Mary Sullivan. Those opinions supported limiting A.S.A. to simple or routine tasks, limited workplace contact, and routine workplace changes. The court also considered psychologist Marlin Trulsen’s opinion that A.S.A. had moderate to occasionally marked difficulty tolerating workplace stress. It agreed with the administrative law judge that this portion of Trulsen’s opinion was inconsistent with his examination findings, the medical record, A.S.A.’s work at the time of the examination, and A.S.A.’s daily activities.

The court noted that treatment records generally described A.S.A.’s mental health as stable when he took his medication. The records commonly showed logical and goal-directed thought processes, intact memory, intact insight and judgment, and no delusions or hallucinations. The court also considered evidence that A.S.A. cared for his son and a puppy, shopped, maintained social contacts, and worked part-time during the relevant period.

The court considered opinions from CNP Therese Sundberg and CNP Heidi A. Greifzu that A.S.A. could not work. It concluded that opinions about whether a claimant is disabled or unable to work address an issue reserved to the Commissioner. It further found that the January 2020 and March 2021 letters were outside the relevant period and did not indicate that they applied to July 2017 through June 2019. The court also found those opinions inconsistent with the medical evidence, conservative treatment, and daily activities.

Court’s Analysis

The court reviewed the administrative decision under the substantial-evidence standard. That standard asks whether the record contains relevant evidence that a reasonable person could accept as adequate to support the agency’s conclusion. The court considered evidence supporting and detracting from the Commissioner’s decision, but it was required to affirm if substantial evidence supported the administrative law judge’s conclusion, even if the evidence could also support a different result.

The court held that substantial evidence supported the residual functional capacity. It found that A.S.A.’s mental impairments were real but that the administrative law judge accounted for them through restrictions to simple, repetitive work, limited contact with coworkers and supervisors, no public contact, and infrequent routine changes. The court also upheld the administrative law judge’s evaluation of A.S.A.’s reported symptoms, finding that the medical findings, medication-controlled symptoms, daily activities, and part-time work supported the conclusion that his statements about the intensity and effects of his symptoms were not fully consistent with the record.

The court additionally noted that a prior 2011 decision granting A.S.A. Supplemental Security Income concerned a different period. It held that the administrative law judge was not required to adopt that earlier decision or give it significant weight when deciding whether A.S.A. was disabled from 2017 through 2019.

Disposition

The court granted the Commissioner’s Motion for Summary Judgment. It dismissed the case with prejudice and ordered that judgment be entered accordingly.