Moua L. v. Saul
- Katherine Menendez
- 0:20-cv-00692
- U.S. District Court · District of Minnesota
- 4
Moua L. v. Saul: Judge Menendez granted Moua L.’s motion, denied the Commissioner’s motion, and remanded for further proceedings.
Moua L. and the Commissioner of Social Security; the case returns to the Social Security Administration for a supplemental hearing and further administrative action.
What happened
In Moua L. v. Saul, the court reviewed both sides’ requests for summary judgment in a Social Security case. The court considered whether the administrative law judge properly evaluated the opinion of Moua L.’s treating primary care physician.
The court found three errors: the administrative law judge did not address the doctor’s opinion that Moua L. would miss at least three workdays per month, did not properly consider the long treatment relationship, and relied on evidence that did not substantially support discounting the opinion. The court also found that the administrative law judge did not adequately account for the changing severity of Moua L.’s mental-health symptoms.
Judge Katherine Menendez granted Moua L.’s motion for summary judgment, denied the Commissioner’s motion, reversed the administrative law judge’s decision, and remanded the case for a supplemental hearing and further administrative action.
The detailed version
- Moua L. v. Saul · No. 0:20-cv-00692
- Katherine Menendez
- May 17, 2021
Background
The parties filed cross-motions for summary judgment, which ask the court to decide whether the administrative decision should stand based on the record. After a hearing, the court ruled from the bench for Moua L. and remanded the case to the Social Security Administration. This order incorporates the court’s oral reasoning and summarizes it.
Reasons for the ruling
The court identified three errors in the administrative law judge’s evaluation of the opinion from Moua L.’s treating primary care physician, Dr. Charlene Ulstad-Warkentien.
First, the administrative law judge did not address Dr. Ulstad-Warkentien’s assessment that Moua L. would be absent from work three or more days per month. Because the administrative law judge did not address that limitation, the court could not effectively review the reasons for giving the opinion little weight.
Second, the administrative law judge did not adequately consider the length, frequency, nature, and extent of the treatment relationship. Dr. Ulstad-Warkentien had treated Moua L. for more than 15 years, had at least seven office visits with her between March 2016 and January 2018, and was heavily involved in her physical and mental-health care. The court concluded that the administrative law judge did not give good reasons for assigning little weight to the doctor’s opinion without addressing these factors or explaining their effect on the doctor’s assessment about work absences.
Third, the court found that any conclusion that the doctor’s opinion was inconsistent with the overall record was not supported by substantial evidence, meaning enough relevant evidence to support the decision. The administrative law judge focused too much on brief periods when Moua L.’s functioning was better and did not adequately consider the fluctuations in her depression and post-traumatic stress disorder symptoms.
The court determined that Moua L.’s trips, limited yard work, occasional knitting and sewing, short-term ability to drive, and limited daily activities did not substantially show that she could consistently attend a full-time job. The record also included repeated emotional distress, hospitalizations, emergency mental-health treatment, several hours of daily personal-care assistance, and a therapist’s opinion consistent with Dr. Ulstad-Warkentien’s assessment.
Disposition
Judge Katherine Menendez ordered that:
- Moua L.’s motion for summary judgment was GRANTED.
- The Commissioner’s motion for summary judgment was DENIED.
- The administrative law judge’s decision was REVERSED, and the case was REMANDED to the Commissioner of Social Security for a supplemental hearing and further administrative action consistent with the opinion, under sentence four of 42 U.S.C. § 405(g).
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.