April A. v. O'Malley

Background

April A. sought review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying an application for Disability Insurance Benefits and Supplemental Security Income. April A. alleged disability beginning April 4, 2019, after amending the alleged onset date at the administrative hearing. The Social Security Administration denied the application initially and on reconsideration. An administrative law judge then held a hearing at which April A., represented by counsel, testified, and a vocational expert provided testimony.

The administrative law judge found several severe impairments, including depression, anxiety, bipolar disorder, post-traumatic stress disorder, obsessive compulsive disorder, gender dysphoria, obesity, traumatic brain injury or post-concussion syndrome, degenerative disc disease, and a left shoulder disorder. The administrative law judge also found allergic rhinitis and celiac disorder to be non-severe impairments. The judge determined that April A. retained the residual functional capacity—the most a person can still do despite physical and mental limitations—to perform light work with restrictions. Those restrictions included limited lifting and carrying, up to six hours of standing and walking and sitting in an eight-hour workday, occasional postural activities, no exposure to certain hazards, occasional overhead reaching, no driving, simple and routine tasks, no public interaction, and only occasional interaction with supervisors and coworkers.

The vocational expert testified that a person with those limitations could perform work as a classifier, inspector or hand packager, and small products assembler. The expert testified that at least 350,000 such jobs existed in the national economy.

Issues and analysis

April A. challenged the residual-functional-capacity finding, arguing that it understated the severity of the physical and mental impairments. April A. also argued that the administrative law judge should have relied more heavily on state-agency medical and psychological opinions. According to April A., the residual functional capacity should have included additional handling restrictions and limits requiring a predictable work environment without time constraints or production quotas.

The court explained that an administrative law judge must evaluate the persuasiveness of prior administrative medical findings, with particular attention to supportability and consistency. Supportability concerns whether objective medical evidence supports a finding; consistency concerns whether it agrees with other relevant medical and nonmedical evidence. The court concluded that the administrative law judge appropriately explained which parts of the state-agency opinions were adopted, which were rejected, and why. The court found sufficient support for rejecting the proposed handling restriction because the record showed only a few instances of slightly reduced grip strength. It also found sufficient support for rejecting the proposed predictable-workplace and no-quota restrictions based on evidence that April A. could manage personal hygiene, prepare food, help with household chores, demonstrate adequate insight, and have normal judgment.

April A. also challenged the vocational expert’s testimony. The court rejected the argument that the testimony was based on an incomplete residual functional capacity because the court had already found that capacity properly formulated. The court also rejected the argument that jobs requiring level-two reasoning conflicted with a limitation to simple, routine tasks. Finally, the court considered whether testimony about jobs available nationally was enough to show that a significant number of jobs were available. The court recognized that regional job information is preferable and that courts have differed on whether national numbers alone are sufficient. But it concluded that the vocational expert’s testimony about 350,000 jobs across three classifications, none apparently specialized or geographically isolated, was sufficient in this case under a common-sense, multi-factor approach.

Disposition

The court held that substantial evidence supported the administrative law judge’s residual-functional-capacity determination and the finding that April A. could perform available work. Judge Douglas L. Micko denied April A.’s motion, granted the Commissioner’s motion, and dismissed the matter with prejudice. The court ordered judgment to be entered accordingly.