Sandra W. v. Kijakazi

Background

Sandra W. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying her application for disability insurance benefits. She alleged disability beginning April 1, 2019, based on a right shoulder rotator cuff tear and surgery, cervical disc disease and stenosis, arm pain, and other conditions. The administrative law judge found several severe impairments, determined that none met or equaled a listed impairment, and assessed her as able to perform light work with frequent bilateral reaching, handling, fingering, and feeling. The administrative law judge concluded at step four that she could perform her past work as a nurse case manager.

The parties filed cross-motions for summary judgment. Sandra W. argued that the administrative law judge improperly relied on unclear vocational-expert testimony and improperly assessed her residual functional capacity, or RFC—the most she could still do despite her impairments. The Commissioner argued that the vocational-expert testimony supported the finding that Sandra W. could perform her past work.

Past Relevant Work and Vocational-Expert Testimony

The court held that the administrative law judge improperly relied on the vocational expert’s testimony concerning Sandra W.’s past work. The vocational expert identified one occupation using a Dictionary of Occupational Titles code that did not appear in that resource. The other code described a medical social-worker occupation, not the nurse case-manager work Sandra W. had described. The court found that the occupation’s title, duties, and stated requirement for social-work training did not match Sandra W.’s past work or training.

Because the administrative law judge relied on that testimony to find that Sandra W. was not disabled, the court concluded that the record did not adequately establish whether she could perform her past work or other work existing in significant numbers in the national economy. The court reversed the Commissioner’s decision and remanded under sentence four of 42 U.S.C. § 405(g) for further administrative proceedings. On remand, the administrative law judge must either properly support a finding that Sandra W. can perform her past relevant work or determine whether the Commissioner has met the step-five burden of showing that she can perform other work.

Residual Functional Capacity

The court rejected Sandra W.’s separate challenge to the RFC assessment. She argued that the assessment failed to account for her knee condition, medication side effects, her testimony, and her treating physician’s opinion. The court found that the administrative law judge considered the record as a whole, including the knee impairment and possible medication effects, and adequately explained why the treating physician’s more restrictive opinion was only partially persuasive.

The court also found substantial evidence supporting the RFC, including medical findings, the medical expert’s opinion, and Sandra W.’s reported daily activities. Although some evidence could support a more restrictive RFC, the court stated that it could not reweigh the evidence or decide the issue anew. It therefore affirmed the RFC assessment.

Disposition

The court granted Sandra W.’s motion for summary judgment in part and denied it in all other respects. It denied the Commissioner’s motion for summary judgment, reversed the Commissioner’s denial of benefits, and remanded the matter for further administrative proceedings consistent with the order. The order additionally states: “This matter is DISMISSED WITH PREJUDICE.”