Jared G. v. Kijakazi

Background

Jared G. sought judicial review of the Commissioner of Social Security’s decision denying his application for disability benefits. He alleged disability based on multiple sclerosis, low vision, cognitive difficulties, fatigue, balance problems, urinary symptoms, and other impairments. An administrative law judge (ALJ) denied the application after a hearing, and the Social Security Appeals Council declined review.

The parties filed cross-motions for summary judgment. Magistrate Judge John Docherty recommended granting the Commissioner’s motion and denying Jared G.’s motion. Jared G. objected to the recommendation, arguing that the ALJ failed to properly evaluate a June 2020 letter from Dr. Gary Beaver and failed to properly evaluate Jared G.’s statements about the intensity and limiting effects of his symptoms.

Dr. Beaver’s Letter

Dr. Beaver’s letter described Jared G.’s multiple sclerosis, reported symptoms, and difficulties with fatigue, cognition, multitasking, sustained attention, anxiety, and irritability. Dr. Beaver concluded that Jared G. could not maintain sustained gainful employment.

The court explained that a medical opinion under the applicable Social Security regulations concerns what a claimant can still do despite an impairment and the claimant’s work-related limitations or restrictions. A statement that a claimant cannot maintain employment addresses an issue reserved for the Commissioner rather than providing a medical opinion about functional abilities. The court also found that Dr. Beaver’s letter summarized symptoms but did not otherwise describe specific limitations or restrictions caused by Jared G.’s impairments. The court therefore concluded that the ALJ did not err by declining to discuss the letter’s conclusion.

Jared G.’s Symptom Statements

Jared G. argued that the ALJ relied on medical imaging showing no active disease but failed to address the same progress note’s discussion of increased cognitive difficulties, including losing his train of thought, slower information processing, and difficulty multitasking. He also challenged the ALJ’s finding that his multiple sclerosis was stable with medication.

The court stated that an ALJ does not have to discuss every medical record and that failing to cite particular evidence does not show that the evidence was ignored. The court found that the ALJ had referenced the relevant progress note elsewhere in the decision, including its discussion of anxiety and reactive depression. The ALJ also considered mental-status examinations, daily activities requiring concentration, statements from Jared G. and medical experts, and other evidence. The court concluded that the ALJ’s finding that Jared G.’s symptom statements were inconsistent with the record, including the finding that his multiple sclerosis was stable, was supported by substantial evidence.

Ruling

Judge John R. Tunheim overruled Jared G.’s objections and adopted the magistrate judge’s Report and Recommendation. The court denied Jared G.’s motion for summary judgment, granted the Commissioner’s motion for summary judgment, and directed that judgment be entered accordingly.