Steve N. v. Kijakazi

Background

Steve N. sought judicial review under 42 U.S.C. § 405(g) of the Social Security Commissioner’s denial of his application for disability insurance benefits. The relevant period was October 31, 2018, through March 31, 2019, his date of last insurance. The administrative judge found that Steve N. had severe chronic pain syndrome, chronic fatigue syndrome, episodic hypersomnia, chronic headaches, depression, bipolar disorder, and personality disorder, but concluded that he was not disabled.

The administrative judge found that Steve N. could not perform his past work but retained the residual functional capacity (RFC)—the most he could do despite his limitations—to perform light work with restrictions on environmental exposure, workplace pace, social interaction, and workplace changes. A vocational expert testified that a person with those restrictions could perform jobs such as mailroom clerk, price marker, or clerical data entry clerk.

Arguments and analysis

Steve N. argued that the administrative judge failed to properly consider his chronic fatigue syndrome, chronic pain syndrome, medical opinions, and journal entries describing fatigue, headaches, excessive sleep, pain, and mental-health symptoms. The court treated these arguments as a challenge to the RFC finding.

The court concluded that the administrative judge had considered the relevant evidence. It relied on the absence of objective testing confirming pathologic hypersomnia, records showing generally intact neurological and musculoskeletal functioning, limited formal treatment for the chronic fatigue and chronic pain syndromes, routine outpatient mental-health treatment, and generally intact memory, concentration, attention, insight, and judgment. The court also noted that Steve N.’s reported daily activities and sporadic work history supported the administrative judge’s assessment.

The court found that the cited doctors had not provided opinions during the relevant period stating that Steve N. was unable to work. It also explained that whether a claimant is disabled is an issue reserved to the Commissioner. The court determined that the administrative judge properly considered Steve N.’s chronic fatigue and chronic pain, including by adding restrictions to the RFC, and that Steve N. had not shown that additional limitations were required.

Holding and disposition

The court reviewed the decision under the substantial-evidence standard, which asks whether the record contains enough relevant evidence for a reasonable person to support the agency’s conclusion. It held that substantial evidence supported both the RFC and the finding that Steve N. was not disabled during the relevant period.

Judge Dulce J. Foster granted the Commissioner’s motion for summary judgment, denied Steve N.’s motion for summary judgment, affirmed the Commissioner’s decision, and dismissed Steve N.’s complaint with prejudice. The order directed that judgment be entered accordingly.