Pa M. v. Kijakazi

Background

Pa M. sought judicial review under 42 U.S.C. § 405(g) of the Social Security Administration’s final decision denying her application for Social Security disability insurance benefits. The administrative law judge found severe impairments involving lower-back pain, both knees, major depressive disorder, anxiety, post-traumatic stress disorder, and a personality disorder. The judge determined that Pa M. had the residual functional capacity—the most she could still do despite her impairments—to perform light work with additional physical, mental, and social restrictions. The judge concluded at the fourth step of the disability process that she could perform her past relevant work as a housekeeper and therefore was not disabled.

The parties filed cross-motions for summary judgment. Pa M. argued that the administrative law judge misrepresented the record and improperly discounted her reports about pain, mental-health symptoms, walking ability, and daily limitations. She also argued that the judge should have given more weight to the opinions of her treating physician, Dr. Mary Yee, than to the opinions of state-agency consultants Dr. Kerri Chung and Dr. Cliff Phibbs and psychologist Dr. Karayusuf.

Court’s Analysis

The court held that substantial evidence supported the administrative law judge’s evaluation of Pa M.’s subjective complaints. The administrative law judge considered inconsistencies between those complaints and clinical findings, treatment history, responses to medication and other conservative care, daily activities, and instances of noncompliance with recommended treatment. The court cited records showing generally normal gait, coordination, strength, and reflexes on many examinations; mild knee changes on imaging; improvement with medication, injections, chiropractic care, exercise, and other conservative measures; and inconsistencies in reports about cane or walker use, walking, shopping, and other activities. The court also found that the record supported the administrative law judge’s assessment of Pa M.’s mental-health complaints, including reported improvement with treatment and inconsistencies between some reported symptoms and examination or activity records.

The court also upheld the weight given to Dr. Yee’s opinions. Because Pa M.’s claim was filed after March 27, 2017, the court applied regulations requiring consideration of the supportability and consistency of medical opinions rather than automatically giving a treating physician’s opinion controlling weight. The court found that Dr. Yee’s restrictive opinions were not supported by objective evidence and were inconsistent with treatment records, examination findings, conservative treatment, and other evidence. The court likewise upheld the weight given to the state-agency consultants because the administrative law judge explained why their opinions were supported and consistent with the record and independently reviewed later evidence. Finally, the court upheld the mental residual-functional-capacity assessment, noting that the administrative law judge added limitations beyond those suggested by Dr. Karayusuf.

Disposition

Judge Becky R. Thorson concluded that the administrative law judge’s credibility findings and residual-functional-capacity determination were supported by substantial evidence and that the decision had to be affirmed. The court’s order states that Pa M.’s Motion for Summary Judgment was DENIED and Kijakazi’s Motion for Summary Judgment was GRANTED, with judgment to be entered accordingly.