David A. P. v. Kijakazi

Background

David A. P. applied for disability insurance benefits and supplemental security income, claiming disability beginning in April 2017 because of back and neck pain, cognitive disorder, depression, attention deficit hyperactivity disorder, and seizures. His applications were denied, and an administrative law judge later found that he was not disabled. The administrative law judge found that David A. P. had several severe impairments, including spine disease, neuropathy, hearing loss, attention deficit hyperactivity disorder, major depressive disorder, neurocognitive disorder, and seizure-related spells.

The administrative law judge determined that David A. P. had the residual functional capacity—the most he could still do despite his impairments—to perform light work with additional physical, hearing, environmental, driving, mental, and social restrictions. Based on testimony from a vocational expert, the administrative law judge found that he could perform jobs such as electronics worker, molding machine tender, and product assembler.

Arguments

David A. P. moved for summary judgment, arguing that the administrative law judge improperly evaluated the medical opinions under the Social Security regulations, improperly assessed the intensity and effects of his symptoms, and used a residual-functional-capacity finding and vocational-expert questions that did not include all limitations identified by his medical providers.

The court reviewed whether the administrative law judge’s decision was supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate. It concluded that the administrative law judge properly considered the supportability and consistency of the medical opinions. The court upheld the treatment of the state-agency consultants’ and Dr. O’Regan’s opinions as somewhat persuasive, and it upheld the finding that the opinions of Dr. Johnson, Terry Barclay, Dr. Sabharwal, and Dr. Anderson were not persuasive. The court explained that those opinions included limitations that were not sufficiently supported by the providers’ findings, conflicted with treatment records or other evidence, or were inconsistent with David A. P.’s prior work history.

The court also concluded that the administrative law judge reasonably evaluated David A. P.’s symptoms. The administrative law judge considered objective testing, treatment history, medication, daily activities, and other evidence. The court further concluded that the administrative law judge was not required to include limitations that he reasonably found unsupported when questioning the vocational expert.

Ruling

Judge Tony N. Leung denied Plaintiff’s Motion for Summary Judgment, ECF No. 16, and granted the Commissioner’s Motion for Summary Judgment, ECF No. 19. The order left the Commissioner’s denial of disability insurance benefits and supplemental security income in place and directed that judgment be entered accordingly.