Jamie E. v. Kijakazi

Background

The Social Security Administration denied Jamie E.’s applications for disability insurance and supplemental security income benefits. She alleged that she became unable to work because of polycystic ovary syndrome, borderline personality disorder, depression, anxiety, post-traumatic stress disorder, attention-deficit hyperactivity disorder, bulimia, and chronic pain.

After a hearing at which Jamie E. testified and was represented by a non-attorney representative, an administrative law judge found that she had several severe impairments, including asthma, chronic pain syndrome, obesity, depressive disorder, anxiety disorder, social phobia, borderline personality disorder, attention-deficit hyperactivity disorder, a trauma- and stressor-related disorder, and cannabis use disorder. The administrative law judge found that none of these impairments, alone or together, met or medically equaled a listed impairment.

The administrative law judge determined that Jamie E. had the residual functional capacity—the ability to work despite her impairments—to perform light work with physical and environmental restrictions. The administrative law judge also limited her to simple, routine, repetitive tasks and occasional superficial contact with other people. Based on that capacity, the administrative law judge found that she could perform her past work as a molding machine tender or production assembler and was not disabled. The Appeals Council declined to review that decision.

Issues and analysis

The parties filed cross-motions for summary judgment, asking the court to decide the case based on the administrative record. The court reviewed whether substantial evidence supported the Commissioner’s decision. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

Jamie E. first argued that the administrative law judge failed to include in the residual functional capacity the restrictions identified by state-agency psychologists, who had limited her to brief and superficial contact with coworkers and the public. The court rejected the argument. It found that the administrative law judge’s limitation to occasional superficial contact, including the definition used in the decision, adequately addressed the persuasive restrictions. The court also explained that the administrative law judge—not the reviewing psychologists—was responsible for determining the residual functional capacity and was not required to adopt every limitation proposed by an expert reviewer.

Jamie E. next argued that the administrative law judge improperly evaluated the opinions of her treating therapist, Dr. Tatyana Zharkova. The court found that the administrative law judge adequately considered whether those opinions were supported by medical evidence and consistent with the rest of the record. The administrative law judge determined that treatment notes did not support the limitations listed on Dr. Zharkova’s check-box form, that most mental-status examinations were normal, and that the opinions relied heavily on Jamie E.’s subjective reports. The court also noted the administrative law judge’s finding that Dr. Zharkova’s statement about worsening symptoms in an employment setting was inconsistent with Jamie E.’s employment history and the record.

Ruling

Judge Eric C. Tostrud held that substantial evidence supported the determination that Jamie E. was not disabled. The court therefore ordered that Jamie E.’s motion for summary judgment be denied, the defendant’s motion for summary judgment be granted, and the matter be dismissed with prejudice. The order directed that judgment be entered accordingly.