Latorres Jr v. Commissioner of Social Security

Background

Esteban Latorres, Jr. applied for disability insurance benefits and supplemental security income, alleging that he became unable to work on May 1, 2015. The Social Security Administration denied his claims. After a hearing, an administrative law judge (ALJ) found that Latorres had major depressive disorder, generalized anxiety disorder, and mood disorder not otherwise specified, but concluded that he was not disabled.

The ALJ found that Latorres could perform simple, routine, low-stress work with limited changes, decision-making, and interaction with other people. Although the ALJ determined that Latorres could not return to his past work as a housecleaner, she found that he could perform other jobs existing in significant numbers in the national economy.

Latorres sought judicial review only of the decision concerning his mental disabilities. He argued that the ALJ improperly evaluated the medical opinions and his reported symptoms. Both sides moved for judgment on the pleadings, which asks the court to decide the case based on the administrative record and the parties’ written arguments.

Legal standard

The court’s review was limited to whether the Commissioner applied the correct legal standard and whether the decision was supported by substantial evidence—relevant evidence that a reasonable person could accept as adequate to support the conclusion. The court was not deciding disability anew.

Because Latorres’s claim was filed before March 27, 2017, the treating-source rule applied. Under that rule, an ALJ must first decide whether a treating medical source’s opinion deserves controlling weight. If it does not, the ALJ must determine the appropriate weight by considering factors such as the treatment relationship, supporting medical evidence, consistency with the record, and the source’s specialty. The ALJ must give good reasons for the weight assigned.

Court’s analysis

The court concluded that the ALJ did not adequately explain her treatment of three opinions from Dr. Pena, Latorres’s treating psychiatrist. The ALJ gave some weight to Dr. Pena’s April 2016 opinion but did not explain which parts she accepted and which parts she rejected. The ALJ gave little weight to Dr. Pena’s October 2017 check-box opinion and to a medical-source statement from Dr. Pena and counselor Carolyn Harden, relying primarily on generally normal mental-status examinations and records that reportedly showed no medication side effects.

The court held that this explanation was insufficient. The ALJ did not identify how the normal findings contradicted Dr. Pena’s specific opinions about Latorres’s limitations in areas such as concentration, attendance, pace, interaction with others, and completing a normal workday. The court also noted that the record appeared to show changes in medication and dosages, contrary to the ALJ’s statement that there had been no such changes.

The court did not decide Latorres’s separate arguments about the ALJ’s evaluation of his reported symptoms or the opinion of consultative examiner Dr. Nikkah. It stated that those issues might be affected by new findings or analysis after the remand.

Disposition

The court granted Latorres’s motion for judgment on the pleadings and denied the Commissioner’s cross-motion for judgment on the pleadings. It remanded the case to the Commissioner for further proceedings consistent with the opinion and ordered the clerk to enter judgment. The opinion did not award benefits or direct a finding that Latorres was disabled.