Mashona M. v. Kijakazi

Background

Biyata Mashona M. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s denial of her application for supplemental security income. The administrative law judge (ALJ) found that Mashona had depression, anxiety, post-traumatic stress disorder, and alcohol use disorder, but determined at step two of the five-step disability process that these impairments were not severe, either alone or together. The ALJ therefore stopped the evaluation without considering the remaining steps.

Mashona challenged the ALJ’s treatment of her reported symptoms and the medical opinions from her mental-health providers, Shantel Giles and Katie Rauber, NP. She argued that the evidence showed more than minimal work-related limitations, particularly in interacting with other people. The Commissioner defended the ALJ’s decision and argued that the record showed improvement with medication, symptoms tied to housing and other situational stressors, gaps in treatment, inconsistent medication use, and possible substance abuse.

Court’s analysis

The court explained that step two uses a low threshold. A claim may be stopped at that stage only when the impairments have no more than a minimal effect on the person’s ability to perform basic work activities. For mental impairments, the ALJ evaluates four areas: understanding, remembering, or applying information; interacting with others; concentrating, persisting, or maintaining pace; and adapting or managing oneself.

The court agreed that substantial evidence supported the ALJ’s findings of mild limitations in understanding, remembering, or applying information; concentrating, persisting, or maintaining pace; and adapting or managing oneself. The medical records generally showed good or normal concentration, fair insight and judgment, and some improvement with medication. The court also found that the ALJ reasonably discounted the reported severity of symptoms in those areas.

The court disagreed with the ALJ’s finding of only mild limitation in interacting with others. The record included Mashona’s anxiety around crowds and strangers, efforts to isolate, thoughts of harming others when in conflict, explosive episodes, shouting at people in the community, and continuing conflict with her roommate. The court found that this evidence was consistent with the limitations described by Giles and Rauber concerning interactions with supervisors and coworkers. The ALJ had focused primarily on the roommate conflict, possible substance abuse, and Mashona’s ability to distance herself from the roommate, without adequately addressing the broader evidence concerning interactions with other people.

The court also found that, if the ALJ relied on inconsistent treatment or medication use to discount Mashona’s symptoms, he needed to consider possible explanations such as homelessness, loss of telephone access, loss of insurance, or the effects of her mental illness. The court further observed that the record did not show missed appointments or medication failures after Mashona resumed treatment in January 2020, contrary to the ALJ’s apparent statement that reduced compliance continued during 2020.

Disposition

The court held that Mashona met the step-two threshold by showing that her impairments severely limited her ability to interact with others. It did not decide the parties’ arguments concerning step three because the ALJ had stopped the analysis at step two. Judge Hildy Bowbeer granted Plaintiff’s motion for summary judgment, denied Defendant’s motion for summary judgment, and remanded the matter to the Commissioner for reconsideration beginning at step three and, if appropriate, continuing through step five. The Commissioner must reconsider Mashona’s reported symptoms and the medical opinions, including possible impairment from substance abuse, alternative explanations for treatment noncompliance, and the effect of her impairments on workplace functioning during reasonably foreseeable situational stressors.