Stacy A. R. v. Kijakazi

Background

Stacy A. R. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying her application for disability insurance benefits. She alleged disability based on, among other conditions, incontinence, osteoarthritis affecting her hands and knee, and difficulty walking.

An administrative law judge initially determined that Stacy was disabled. The Appeals Council later modified that decision and found that she was not disabled. The Appeals Council concluded that Stacy could perform sedentary work with specified physical, environmental, and mental limitations and could perform her past work as a customer service representative/order clerk.

Stacy asked the district court to reverse the Commissioner’s decision and remand the case. She argued that the Appeals Council improperly determined that her incontinence did not require additional bathroom breaks, that her hand problems did not require regular hand-stretching breaks, and that she did not need a cane. She withdrew a separate argument about the appointment of a former Commissioner, so the court did not consider it.

Court’s analysis

The court applied substantial-evidence review, meaning it examined whether the record contained enough evidence to support the Commissioner’s decision and whether the agency applied the law correctly.

The court rejected Stacy’s challenge concerning incontinence and hand-soreness breaks. It held that substantial evidence supported the Commissioner’s findings that Stacy did not require unscheduled bathroom breaks or hand-stretching breaks in her residual functional capacity, which is the most a person can do despite medical limitations. The court noted evidence that medical professionals had not documented a need for the claimed bathroom breaks, that providers had not identified the asserted hand-break limitation, and that some of Stacy’s activities were inconsistent with the claimed restrictions. The court stated that it could not reweigh the evidence.

The court reached a different conclusion regarding cane use. The record showed that a doctor had prescribed Stacy a cane and that various providers documented different levels of cane use during the relevant period. The Appeals Council did not address the cane in its residual-functional-capacity analysis or explain whether the cane prescription and use were persuasive or unpersuasive. The court held that this omission prevented meaningful judicial review.

The court explained that a cane must be medically necessary or medically required before limitations from its use must be included in the residual functional capacity. Determining that issue requires medical documentation establishing the need for the device and describing the circumstances in which it is needed. The court did not decide whether Stacy actually required a cane. Instead, it held that the Commissioner had to address the evidence and explain the decision.

Disposition

Judge John F. Docherty ordered that Stacy’s Motion for Summary Judgment was granted in part and denied in part, the Commissioner’s Motion for Summary Judgment was denied, and the Commissioner’s decision was reversed. The case was remanded under sentence four of 42 U.S.C. § 405(g) for further administrative proceedings. Those proceedings must determine whether the record shows that Stacy requires a cane as a medically necessary or medically required assistive device, under what circumstances, and whether that determination changes the later steps of the disability evaluation.