Natalie F. v. O'Malley

Background

Natalie F. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying her applications for Disability Insurance Benefits and Supplemental Security Income. She alleged that she became disabled beginning May 26, 2020. The Social Security Administration denied her applications initially and on reconsideration. An administrative law judge (ALJ) held a telephone hearing on November 17, 2021, at which Natalie F. was represented by counsel, testified, and questioned a vocational expert.

The ALJ found that Natalie F. had severe impairments involving her spine and right knee. The ALJ also considered depression, anxiety, and a history of drug addiction but found those mental impairments non-severe because they caused no more than minimal limitations in basic work activities. The ALJ determined that Natalie F. retained the residual functional capacity (RFC)—the most work a person can perform despite physical and mental limitations—to perform light work with restrictions on climbing, stooping, crouching, and crawling. The RFC also limited her to simple instructions, low-stress work, no piece work or fast-moving assembly-line work, and no more than occasional interaction with the public, coworkers, and supervisors.

Based on vocational expert testimony, the ALJ found that Natalie F. could perform work as a mail clerk, housekeeper or cleaner, and small-products assembler. The vocational expert testified that at least 223,000 such jobs existed in the national economy. The ALJ therefore found her not disabled. After the Appeals Council denied review, Natalie F. sought review in federal court. She proceeded without a lawyer in that federal-court case.

Arguments and standard of review

Natalie F. argued that the ALJ failed to account for the combined effects of her physical and mental impairments. Liberally construing her filings, the court understood her to argue that the ALJ understated the severity of her mental impairments, assessed an RFC that did not reflect her limitations, and improperly relied on the vocational expert’s testimony about the number of available jobs. The Commissioner argued that substantial evidence supported the ALJ’s decision as a whole.

The court reviewed whether the ALJ’s decision was supported by substantial evidence in the record as a whole and whether the ALJ made a legal error. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion. The court explained that it could not reweigh the evidence or substitute its own judgment for the ALJ’s when the record supported the ALJ’s findings.

Mental impairments

The court upheld the ALJ’s conclusion that Natalie F. had only mild limitations in four areas: understanding, remembering, or applying information; interacting with others; concentrating, persisting, or maintaining pace; and adapting or managing herself. The court cited evidence that she prepared meals, performed simple maintenance, shopped, spent time with family, managed funds, maintained personal hygiene, cared for her child, and provided health information.

The court also found that the ALJ appropriately evaluated the medical evidence. The ALJ considered state-agency psychological consultants’ findings of mild limitations, Natalie F.’s reports that her anxiety had improved and her depression was controlled, mental-status findings, and her daily activities. The court acknowledged that some of Natalie F.’s testimony could have supported more significant limitations, but concluded that the testimony, viewed with the medical and other evidence, did not undermine the ALJ’s findings.

Residual functional capacity

The court held that substantial evidence supported the RFC. Although the ALJ found only mild mental impairments, the ALJ included additional mental restrictions as a precaution, including simple instructions, low-stress work, and limited interaction with others. For physical limitations, the ALJ restricted Natalie F. to light work rather than adopting state-agency medical consultants’ view that she could perform medium work and frequently climb. The ALJ relied in part on her lumbar facet arthropathy and physical therapy for right-knee pain.

The court concluded that the record did not require greater restrictions and that the RFC remained within the permissible range of choices available to the ALJ. The court therefore found no error in the RFC determination.

Vocational expert testimony

The court also upheld the ALJ’s reliance on the vocational expert. The expert testified that Natalie F. could not perform her prior salesclerk job as actually performed because it required medium work. With the mental restrictions included in the RFC, the expert concluded that she could perform the mail-clerk, housekeeper-or-cleaner, and small-products-assembler jobs.

The court determined that the vocational expert’s testimony was based on a hypothetical that included all limitations the ALJ had properly found. Although the court stated that regional job numbers would have been preferable, it held that testimony about at least 223,000 jobs nationwide across three representative occupations was substantial evidence that a significant number of jobs were available.

Disposition

The court affirmed the Commissioner’s decision. Judge Douglas L. Micko ordered that Natalie F.’s request for reversal be denied and the Commissioner’s request for affirmance be granted. The opinion also states that the matter was dismissed with prejudice, and judgment was ordered to be entered accordingly.