Mark L. v. Kijakazi
- Katherine Menendez
- 0:21-cv-02281
- U.S. District Court · District of Minnesota
- 6
In Mark L. v. Kijakazi, Judge Menendez overruled Mark L.’s objections, denied his summary-judgment motion, and granted Kijakazi’s.
Mark L.’s claims for disability benefits and supplemental security income were denied, while the Acting Commissioner of Social Security prevailed on summary judgment.
What happened
In Mark L. v. Kijakazi, Mark L. challenged the denial of his applications for disability benefits and supplemental security income. He argued that the administrative law judge did not properly evaluate his therapist’s medical opinions.
The court concluded that the administrative law judge adequately considered whether the therapist’s opinions were supported by her treatment records and consistent with other evidence. The court pointed to largely normal mental-status findings, improvement with therapy, and Mark L.’s daily activities.
Judge Menendez overruled Mark L.’s objections, accepted the magistrate judge’s report and recommendation, denied Mark L.’s motion for summary judgment, and granted the defendant’s motion for summary judgment.
The detailed version
- Mark L. v. Kijakazi · No. 0:21-cv-02281
- Katherine Menendez
- Mar. 29, 2023
Background
Mark L. applied for supplemental security income and disability benefits in May 2019. The Social Security Administration denied the applications, and Administrative Law Judge Corey Ayling later issued a decision denying benefits. The Appeals Council declined review, making the administrative law judge’s decision the Commissioner’s final decision.
Mark L. sought judicial review and moved for summary judgment, meaning he asked the court to rule in his favor based on the administrative record. Acting Commissioner Kilolo Kijakazi also moved for summary judgment. Magistrate Judge Leo I. Brisbois recommended denying Mark L.’s motion and granting the defendant’s motion. Mark L. objected, mainly arguing that the administrative law judge failed to properly evaluate the opinions of his therapist, Katherine Schmidtbauer.
Court’s Analysis
The court reviewed the challenged portions of the report and recommendation independently. In reviewing the denial of disability benefits, the court asked whether the administrative law judge’s decision was supported by substantial evidence—evidence sufficient for a reasonable person to support the conclusion, even if other evidence points the other way.
Under the applicable regulation, an administrative law judge evaluating a medical opinion must explain the opinion’s supportability and consistency. Supportability concerns the medical evidence and explanations offered by the source. Consistency concerns whether the opinion agrees with evidence from other medical and nonmedical sources.
The court held that the administrative law judge adequately addressed both factors. The administrative law judge found Schmidtbauer’s opinions insufficiently supported by her own treatment records, which showed largely normal mental-status examinations and a good response to therapy. The administrative law judge also found the opinions inconsistent with other evidence, including largely unremarkable mental-status findings from other treatment providers and Mark L.’s extensive daily activities. The court also agreed that some of the opinions appeared to rely on Mark L.’s subjective reports.
Disposition
The court accepted the report and recommendation, overruled Mark L.’s objections, denied Mark L.’s motion for summary judgment, and granted the defendant’s motion for summary judgment. The court therefore upheld the administrative law judge’s denial of benefits.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.