Maysee T. L. v. Kijakazi

Background

Maysee T. L. challenged the Commissioner of Social Security’s denial of her applications for disability insurance benefits and supplemental security income. She alleged disability beginning in September 2016 based on physical conditions including pain and numbness in her hands and feet, peripheral neuropathy, spine disorders, plantar fasciitis, gout, and other impairments.

After a hearing, the administrative law judge found that Maysee had severe impairments including spine disorders, major joint dysfunction, peripheral neuropathy, and right trigger finger. The administrative law judge determined that she had the residual functional capacity—the most she could do despite her limitations—to perform medium work with several restrictions. The administrative law judge concluded that she could perform her past relevant work as a medical assembler and was therefore not disabled.

The parties filed cross-motions for summary judgment. Maysee argued that the administrative law judge failed to classify plantar fasciitis as a severe impairment, omitted restrictions related to her neuropathy, spine disorders, and plantar fasciitis, improperly evaluated her pain complaints, and improperly relied on prior administrative medical findings.

Court’s analysis

The court rejected Maysee’s argument that the failure to list plantar fasciitis as a severe impairment required remand. Although the administrative law judge did not specifically name plantar fasciitis, the decision discussed her foot pain, imaging showing foot enthesopathy, and her reported limits on standing and walking. The court also concluded that Maysee had not identified an additional functional restriction that should have been included in the residual-functional-capacity assessment because of plantar fasciitis.

The court likewise concluded that Maysee had not shown what specific additional restrictions should have been included for peripheral neuropathy, spine disorders, or plantar fasciitis. It did not reach the remainder of her challenges to the residual-functional-capacity determination after finding error in the administrative law judge’s evaluation of her pain-related statements.

In evaluating pain, the administrative law judge considered medical findings, treatment effectiveness, and daily activities. The court found that the administrative law judge accurately described evidence both supporting and detracting from Maysee’s allegations, including imaging findings, abnormal and normal examinations, treatment responses, and inconsistent use of assistive devices. But the court was not persuaded that the administrative law judge’s reliance on reports of “strenuous activity”—including moving through heavy snow, gardening, walking, and being somewhat active—was supported by substantial evidence when compared with the limited nature of Maysee’s regular activities and her need for personal-care assistance.

Disposition

The court ordered that Maysee’s motion for summary judgment was GRANTED IN PART and DENIED IN PART and that the Commissioner’s motion for summary judgment was GRANTED IN PART and DENIED IN PART. The court VACATED the administrative law judge’s residual-functional-capacity determination and decision as to steps four and five of the disability analysis. It REMANDED the matter to the Commissioner under sentence four of 42 U.S.C. § 405(g) for further proceedings. The order did not award disability benefits and did not decide the remaining challenges to the residual-functional-capacity determination.