Asha S. v. Kijakazi

Background

Asha S. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying her applications for disability insurance benefits and supplemental security income. She alleged that her disability began on March 27, 2018. The Social Security Administration denied the applications initially and on reconsideration. After a hearing, an Administrative Law Judge (ALJ) found that Asha S. was not disabled, and the Appeals Council declined further review.

The ALJ found severe impairments including major depressive disorder, post-traumatic stress disorder, schizoaffective disorder, degenerative disc disease of the lumbar spine, mild degenerative joint disease in both hips, migraine headaches, and obesity. The ALJ determined that Asha S. could perform light work with restrictions on climbing, postural activities, environmental exposure, workplace hazards, task complexity, and contact with other people. The ALJ found that she could not return to her past work as a packager, housekeeper, or caregiver, but could perform other jobs existing in significant numbers in the national economy.

Issues and Arguments

Asha S. raised two issues. First, she argued that the ALJ failed to give adequate weight to opinions and observations from her treating providers and consulting examiners. Second, she argued that the ALJ’s residual functional capacity (RFC)—the most a person can still do despite her limitations—was not supported by substantial evidence.

The Commissioner argued that the ALJ properly evaluated the medical opinions under the regulations applicable to claims filed on or after March 27, 2017. Those regulations do not automatically give controlling weight to a treating provider’s opinion. Instead, they emphasize supportability and consistency with the record.

Court’s Analysis

Judge Thorson concluded that the ALJ properly found Jennifer Neumann’s opinions unpersuasive. Neumann’s 2018 and 2019 statements addressed whether Asha S. could sustain employment but did not describe specific work-related functional limitations. The court explained that whether a claimant is disabled or able to work is an issue reserved for the Commissioner. The court also found that Neumann’s January 2020 opinion lacked a function-by-function assessment and sufficient explanation for the proposed breaks, position changes, absences, and unscheduled time off. The court determined that those limitations were inconsistent with treatment records showing generally normal musculoskeletal and neurological findings, independent walking, and no need for an assistive device.

The court also upheld the ALJ’s treatment of Joseph Wilson’s opinions. Wilson’s statement that Asha S. could not maintain gainful employment addressed an issue reserved for the Commissioner. His 2018 and 2019 check-box forms identified substantial limitations but did not explain them. The court found those opinions inconsistent with treatment records describing Asha S. as cognitively intact, well groomed, cooperative, goal directed, and having normal memory and good attention, apart from anxious and depressed mood.

The court found no error in the ALJ’s treatment of the consulting opinions. The ALJ found Debra Moran’s opinion partially persuasive and incorporated its limitations into the RFC. The ALJ found the physical consultants’ opinions partially persuasive, accepting their light-work and environmental restrictions but rejecting their vision limitations because the record showed that Asha S.’s vision was corrected with glasses. The ALJ found the psychology consultants’ opinions persuasive because they were supported by and consistent with treatment records showing generally normal mental-status findings.

The court also concluded that the ALJ was not required to formally evaluate certain other assessments. Dr. A. Neil Johnson’s evaluation did not identify specific work-related functional limitations. Janise Trueblood was a physical therapist, not an acceptable medical source under the applicable regulations, so her observations were not treated as a medical opinion requiring a formal persuasiveness analysis. The court noted that the ALJ nevertheless reviewed Asha S.’s physical-therapy records when evaluating the RFC.

RFC and Disposition

Judge Thorson held that substantial evidence supported the ALJ’s RFC determination. Although some evidence indicated physical and mental limitations, other evidence showed normal gait and movement, normal range of motion, sensations, reflexes, and motor strength, as well as generally stable mental findings. The court also noted evidence that hallucinations improved with medication and that state-agency consultants concluded Asha S. could perform light work or simple, repetitive tasks.

The court held that it could not reweigh the evidence or reverse merely because the record might also support a different conclusion. It therefore denied Asha S.’s motion for summary judgment and granted the Commissioner’s motion for summary judgment. The order directed that judgment be entered accordingly.