Santana v. Commissioner of Social Security

Background

Olga Lydia Santana sought review under 42 U.S.C. §§ 405(g) and 1383(c) of the Commissioner’s final decision denying her application for disability-related Supplemental Security Income. She applied in 2015 and initially alleged disability beginning January 7, 2012; her counsel later amended the alleged onset date to October 1, 2015. After a hearing, Administrative Law Judge David Suna found that Santana was not disabled. The Appeals Council denied review, making the administrative law judge’s decision the Commissioner’s final decision.

Santana appeared at the administrative hearing with counsel. The administrative record included treatment records, consultative psychological and physical examinations, and evidence concerning major depressive disorder, hypertension, obesity, and osteoarthritis of both knees.

Administrative Law Judge’s Decision

The administrative law judge applied the five-step disability analysis. He found that Santana had not engaged in substantial gainful activity, had severe impairments including major depressive disorder, hypertension, obesity, and bilateral knee osteoarthritis, and did not have an impairment that met or equaled a listed impairment.

The administrative law judge found that Santana retained the residual functional capacity—the most she could still do despite her impairments—to perform light work with restrictions. Those restrictions included limited use of foot controls, climbing, balancing, stooping, kneeling, crouching, and crawling; no climbing of ladders, ropes, or scaffolds; limits on task complexity, workplace changes, and interaction with supervisors and coworkers; no contact with the public; five percent off-task time; and an average of one unscheduled absence per month. The administrative law judge found that Santana had no past relevant work but could perform other jobs existing in significant numbers in the national economy.

Arguments on Review

Santana raised three main arguments: the administrative law judge should have given controlling weight to the opinion of her treating psychiatrist, Dr. Donn Wiedershine; the physical residual-functional-capacity finding was not supported by substantial evidence; and the administrative law judge did not properly consider her obesity. The Commissioner argued that the administrative law judge used the correct legal standards and that substantial evidence supported the decision.

Court’s Analysis

The court reviewed whether substantial evidence supported the Commissioner’s decision and whether the correct legal standards were applied. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

As to Dr. Wiedershine’s opinion, the court held that the administrative law judge adequately explained why he gave it only partial weight rather than controlling weight. The opinion described marked limitations in several work-related mental abilities and predicted that Santana would miss work more than three times each month. The court recognized that the administrative law judge incorrectly considered whether Dr. Wiedershine was familiar with the Social Security Administration program, but found that the administrative law judge gave other sound reasons for discounting the opinion.

Those reasons included inconsistencies between Dr. Wiedershine’s opinion and his treatment notes, which often described improvement or stability with medication; inconsistencies with Santana’s reported daily activities, including cooking, cleaning, shopping, using public transportation, managing money, reading, and socializing; and inconsistencies with other substantial evidence in the record. The court also upheld the administrative law judge’s decision to give significant weight to the opinions of consultative psychologists Dr. John Nikkah and Dr. Arlene Broska because their opinions were more consistent with the record as a whole. The court stated that resolving conflicting medical evidence was within the administrative law judge’s authority.

The court also rejected Santana’s challenge to the physical residual-functional-capacity finding. It explained that the administrative law judge did not reject Dr. Ram Ravi’s opinion but gave it partial weight and relied on his assessment that Santana could occasionally lift and carry up to 20 pounds and could sit, stand, and walk for specified periods. The administrative law judge also considered the limited treatment record concerning Santana’s knee pain, the examination findings, and her daily activities.

Finally, the court concluded that the administrative law judge adequately considered obesity. The administrative law judge treated obesity as a severe impairment and considered its effects together with Santana’s hypertension and osteoarthritis when determining her physical restrictions.

Disposition

Judge Paul E. Davison denied Santana’s motion for judgment on the pleadings and granted the Commissioner’s motion for judgment on the pleadings. The court therefore upheld the Commissioner’s denial of benefits. The Clerk was directed to terminate the pending motions and close the case.