Bridgett J. v. Kijakazi

Background

Bridgett J. sought judicial review under 42 U.S.C. § 405(g) of the Social Security Commissioner’s decision on her application for disability insurance benefits. She alleged that her disability began on June 9, 2015. An Administrative Law Judge found that she was not disabled through March 31, 2019, the date she was last insured. On review, the Social Security Appeals Council changed that result in part: it found Bridgett J. disabled from January 31, 2017, through December 16, 2018, but not disabled beginning December 17, 2018.

The Appeals Council concluded that, during the earlier period, Bridgett J.’s recurring gastrointestinal problems required significant hospital treatment and would cause her to miss more than two days of work per month. It found that her condition improved after December 16, 2018, and that she could perform a range of light work.

Parties’ Positions

Bridgett J. challenged the finding that her disability ended after December 16, 2018. She argued that her continuing emergency-room visits and medical problems showed that she remained disabled.

The Commissioner argued that the Appeals Council properly found a decrease in the severity of Bridgett J.’s gastrointestinal symptoms and an increase in her residual functional capacity, meaning the most work she could do despite her limitations.

Court’s Analysis

The court reviewed whether substantial evidence supported the Commissioner’s decision. The court noted that, before December 16, 2018, Bridgett J. had sought treatment at St. Cloud Hospital approximately fifty times for abdominal pain and had sometimes been admitted for several days. After she was prescribed Belbuca in December 2018, she stopped visiting the emergency room for several weeks, reported that her pain was managed and her abdominal symptoms had improved, and stopped taking Zofran for nausea. Follow-up examinations in January, February, and April 2019 showed improvement, including no acute distress and generally normal findings.

The court considered Bridgett J.’s two March 2019 emergency-room visits but found that she was not admitted, appeared well, had normal examinations, and left after being told that narcotics would not be prescribed. The court also considered later 2019 medical records, including visits for abdominal pain, headaches, and treatment involving a spinal cord stimulator. It found that these records did not show the increased impairment necessary to overturn the Appeals Council’s decision. The court emphasized that it could not reweigh the evidence or reverse merely because some evidence might support a different result.

Ruling

Judge Becky R. Thorson held that substantial evidence supported the Appeals Council’s conclusion that Bridgett J.’s gastrointestinal impairments decreased in severity and her residual functional capacity increased after December 16, 2018. The court therefore affirmed the Commissioner’s decision, denied Bridgett J.’s motion for summary judgment, and granted the Commissioner’s motion for summary judgment.