David C. v. Kijakazi

Background

David C. applied for supplemental security income benefits in July 2019, alleging disability beginning on July 15, 1997. He identified bipolar disorder, depression, anxiety, attention deficit hyperactivity disorder, communication disorder, borderline intellectual functioning, Osgood-Schlatter disease, chronic back pain, sleep apnea, and headaches as disabling conditions.

The Social Security Administration denied the application initially and on reconsideration. After a hearing, an administrative law judge found that David C. had severe impairments involving back pain, sleep apnea, headaches, bipolar disorder, anxiety disorder, and attention deficit hyperactivity disorder. The administrative law judge determined that his impairments did not meet or medically equal a listed impairment. She found that he could perform medium-level work with physical restrictions, perform simple and routine tasks, have no interaction with the public, and have occasional interaction with coworkers and supervisors. Based on that assessment, she found that jobs existed in significant numbers in the national economy that he could perform and concluded that he was not disabled. The Appeals Council denied review.

Issue

David C. challenged the administrative law judge’s decision on one ground. He argued that the administrative law judge failed to include all restrictions recommended by state agency psychologists, even though she found their opinions persuasive. In particular, the psychologists had recommended brief and superficial contact with coworkers and supervisors and no contact with the public. David C. argued that “superficial” interaction is different from “occasional” interaction and that the administrative law judge therefore should not have allowed occasional interaction with coworkers and supervisors without further explanation.

Court’s Analysis

The court explained that judicial review was limited to whether the decision was supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate. It also explained that an administrative law judge does not have to adopt every limitation in an opinion the judge finds persuasive. The administrative law judge must assess the claimant’s residual functional capacity—the most the claimant can still do despite his impairments—based on all relevant evidence.

The court concluded that the administrative law judge reasonably relied on evidence beyond the psychologists’ recommendations. That evidence included David C.’s work helping train new employees at a grocery store, his positive interactions with coworkers, his statement that he was friends with his boss, and his consideration of applying for a management position. The court determined that this evidence supported allowing occasional interaction with coworkers and supervisors rather than limiting those interactions to superficial contact.

Disposition

Judge Michael J. Davis concluded that substantial evidence supported the administrative law judge’s determination that David C. was not disabled. The court ordered that David C.’s motion for summary judgment was DENIED, the Commissioner’s motion for summary judgment was GRANTED, and the matter was DISMISSED WITH PREJUDICE. The court directed that judgment be entered accordingly.