Lisa B. v. Kijakazi

Background

Lisa B. applied for supplemental security income in February 2020, alleging disability beginning December 26, 2019. She identified anxiety, arthritis, back problems, shoulder problems, hearing impairments, headaches, depression, and pinched nerves. Her application was denied initially and again on reconsideration. After a hearing, an Administrative Law Judge (ALJ) found that Lisa B. had several severe impairments, including hearing loss with bilateral bone-anchored hearing-aid implantation, obesity, degenerative disc disease, thumb conditions, migraines, shoulder impingement, knee osteoarthritis, generalized anxiety disorder, and major depressive disorder.

The ALJ determined that Lisa B. retained the capacity for sedentary, unskilled work subject to physical and mental restrictions. Because the ALJ found that jobs existed in significant numbers in the national economy that she could perform, the ALJ concluded that she was not disabled. The Social Security Appeals Council declined to review that decision, leading to this lawsuit.

Lisa B.’s Arguments

Lisa B. argued that the ALJ failed to properly evaluate the opinions of Dr. A. Neil Johnson, a medical consulting examiner, and Ms. Tara L. Tait, her treating therapist. Social Security regulations require an ALJ to evaluate medical opinions, including their supportability by objective evidence and their consistency with other evidence. The court explained that these are the two most important factors, although an ALJ does not have to discuss every conflicting piece of evidence or use particular wording.

Regarding Dr. Johnson’s opinion, the court noted that his examination showed mostly normal or near-normal findings, including generally normal ranges of motion, although there were some limitations and Lisa B. reported using a cane or crutch several times a week. The court concluded that the ALJ adequately discussed the examination findings and the medical record and had substantial evidence for finding Dr. Johnson’s opinions unpersuasive.

Regarding Ms. Tait’s opinion, the court noted that her treatment notes generally described normal mental-status examinations, apart from depressed and anxious mood, and often described Lisa B.’s depression as improving and anxiety as stable or improving. Ms. Tait’s later questionnaire identified marked, extreme, and moderate limitations in various work-related functions. The court concluded that the ALJ’s discussion of the mental-health records adequately addressed the requirements for evaluating that opinion.

Ruling

The court held that substantial evidence supported the ALJ’s determination that Lisa B. was not disabled. The court therefore ordered that Lisa B.’s motion for judgment was DENIED, the Commissioner’s motion for summary judgment was GRANTED, and the matter was DISMISSED WITH PREJUDICE. Judgment was ordered to be entered accordingly.

The opinion refers to Dr. Johnson as “Dr. Nelson” in several later passages. The text does not explain whether this is a typographical error or reflects a different person.