Stephanie B. v. Kijakazi
- Jerry Blackwell
- 0:22-cv-00837
- U.S. District Court · District of Minnesota
- 3
In Stephanie B. v. Kijakazi, Judge Blackwell upheld the denial of disability benefits, denying Stephanie B.’s summary-judgment motion and granting the Commissioner’s.
Stephanie B.’s claim for Social Security disability benefits was denied, and the Commissioner’s denial was left in place.
What happened
Stephanie B. challenged the Social Security Commissioner’s decision denying her application for disability benefits. Both sides asked the court to grant summary judgment, which would resolve the case based on the record without a trial.
Stephanie B. argued that the administrative law judge did not properly evaluate the medical opinions of Dr. Galindo and Dr. Wiger. The court concluded that the administrative law judge adequately considered whether those opinions were supported by medical evidence and that substantial evidence supported the finding about Stephanie B.’s work-related limitations.
Judge Jerry W. Blackwell overruled Stephanie B.’s objection, accepted the magistrate judge’s recommendation, denied Stephanie B.’s motion for summary judgment, and granted the Commissioner’s motion for summary judgment.
The detailed version
- Stephanie B. v. Kijakazi · No. 0:22-cv-00837
- Jerry W. Blackwell
- May 11, 2023
Background
Stephanie B. sued to challenge the Acting Commissioner of Social Security’s denial of her application for disability benefits. Both parties filed motions for summary judgment. United States Magistrate Judge David T. Schultz recommended denying Stephanie B.’s motion and granting the Commissioner’s motion. Stephanie B. timely objected to that recommendation.
Issue and analysis
The objection concerned whether the administrative law judge (ALJ) complied with 20 C.F.R. § 404.1520c when evaluating the medical opinions of Dr. Galindo and Dr. Wiger. That regulation requires the ALJ to consider, among other things, the opinions’ supportability and consistency, and to explain how those factors were considered.
The district court independently reviewed the portions of the recommendation to which Stephanie B. objected. It agreed with the magistrate judge’s analysis and conclusions. The court determined that the ALJ sufficiently addressed the supportability of Dr. Galindo’s and Dr. Wiger’s opinions by discussing their treatment and examination notes. The court also determined that substantial evidence supported the ALJ’s finding about Stephanie B.’s residual functional capacity, meaning her remaining ability to perform work-related activities. Because the record supported the ALJ’s decision, the court declined to disturb it.
Ruling
Judge Jerry W. Blackwell ordered that:
- Stephanie B.’s objection was overruled. - The Report and Recommendation was accepted. - Stephanie B.’s motion for summary judgment was denied. - The Commissioner’s motion for summary judgment was granted.
The court ordered judgment to be entered accordingly.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.