Jean C. v. Saul

Background

The parties filed cross-motions for summary judgment. Jean C. challenged the Commissioner of Social Security’s denial of disability benefits. The court held a hearing on June 22, 2021, and later issued this written order summarizing its ruling from the bench.

Past Relevant Work

Jean C. argued that the administrative law judge (ALJ) erred at step four of the disability-benefits evaluation by finding that her 2012 housekeeping job qualified as past relevant work. The court explained that past relevant work must have been performed recently enough, for long enough to learn the job, and at the level of substantial gainful activity (SGA). The parties did not dispute the job’s recency or duration; the dispute concerned SGA.

Jean C. calculated her average monthly earnings by dividing $10,648.50 in 2012 earnings by twelve months. The court concluded that the earnings should instead be evaluated based on the months actually worked. Her testimony indicated that she worked the housekeeping job for six to nine months, while her work-history report listed five months. The report also stated that she earned $8.50 per hour and worked eight hours per day, five days per week. The court concluded that this supported monthly earnings of approximately $1,460, above the $1,010 monthly amount needed to reach SGA levels.

Jean C. also argued that some of the 2012 earnings may have come from an assembly job she performed for the same temporary agency. The court found that the record did not establish what portion of the earnings came from that job. It nevertheless concluded that the evidence supported the ALJ’s finding and that Jean C. had not shown an error in the step-four determination. The court also rejected her argument that the ALJ had not adequately explained the past-relevant-work finding, concluding that the written decision and cited earnings records sufficiently explained it.

Residual Functional Capacity and Headaches

The court concluded that substantial evidence—relevant evidence sufficient to support the finding—supported the ALJ’s residual functional capacity determination. It found that the record supported the conclusion that Jean C.’s headaches became less frequent and severe with medication and more manageable with conservative treatment. Her daily activities were also consistent with the residual functional capacity adopted by the ALJ.

The court further found no error in the ALJ’s evaluation of the opinion of Dr. Hernandez, Jean C.’s treating neurologist. The ALJ gave that opinion little weight because it did not specifically assess functional limitations caused by the headaches and was not entirely consistent with Dr. Hernandez’s treatment notes.

Disposition

The order states that Ms. L.’s motion for summary judgment was denied, the Commissioner’s motion for summary judgment was granted, the ALJ’s decision was affirmed, and the case was dismissed with prejudice. The caption identifies the plaintiff as Jean C., but the first disposition item refers to “Ms. L.”; the opinion does not explain that discrepancy. Judgment was ordered to be entered accordingly.