Quiles v. Saul

Background

Josephine Quiles sought review of an administrative law judge’s decision finding her ineligible for disability insurance benefits under Title II of the Social Security Act and Supplemental Security Income under Title XVI. The administrative law judge found that Quiles had several severe impairments, including obesity, spinal conditions, cervical radiculopathy, an ankle fracture, migraines, and sleep apnea. The administrative law judge determined that Quiles had the residual functional capacity to perform light work, with occasional kneeling, stooping, and stair climbing. The administrative law judge found that Quiles could not perform her past relevant work but could perform other jobs existing in significant numbers in the national economy.

Quiles moved to remand the case for further administrative proceedings. The Commissioner moved for judgment on the pleadings, asking the court to uphold the administrative decision. Quiles argued that the administrative law judge improperly evaluated the medical and other evidence, her reports of pain, her daily activities, her obesity, and the opinions of her treating orthopedic surgeon, Dr. William Barrick, and consultative examiners Dr. George Wootan and Dr. Allen Meisel.

Disability Insurance Benefits

Quiles filed her disability-insurance application before March 27, 2017, so the treating-physician rule applied. Under that rule, a well-supported opinion from a treating medical source that is not inconsistent with the record generally receives controlling weight. If the opinion does not receive controlling weight, the administrative law judge must give good reasons and consider factors such as the length and nature of the treatment relationship, supporting evidence, consistency with the record, and the physician’s specialization.

The court found that the administrative law judge failed to apply that rule properly to Dr. Barrick. The administrative law judge gave slight weight to Dr. Barrick’s opinion that Quiles had a marked partial disability and was limited to light work. The court found that the administrative law judge’s explanation—that Dr. Barrick’s opinion was prepared for a different government agency—was not a valid reason to discount it because Dr. Barrick was Quiles’s longtime treating physician. The court also found that the administrative law judge failed to address Dr. Barrick’s February 23, 2016 opinion that Quiles should avoid bending, twisting, lifting, and driving and could not perform sedentary or light employment.

The court further found that the administrative law judge did not discuss the required treating-physician factors and did not provide adequate reasons for giving Dr. Barrick’s opinion only slight weight. That failure was legal error requiring remand. The court also directed that Quiles’s evaluation of her pain and related limitations be revised on remand because the administrative law judge did not discuss Dr. Barrick’s opinions or medical records in that evaluation.

The court rejected Quiles’s argument that the administrative law judge had to follow Social Security Ruling 96-6p when evaluating Dr. Wootan’s and Dr. Meisel’s opinions. The ruling had been rescinded on March 27, 2017, and was not in effect when the administrative law judge issued the decision. The court also found no error in the administrative law judge’s consideration of Quiles’s obesity, noting that obesity was identified as a severe impairment, its interaction with sleep apnea was considered, and Quiles did not identify additional limitations that should have been included in the residual functional capacity assessment because of obesity.

Supplemental Security Income

Quiles filed her Supplemental Security Income application after March 27, 2017. The treating-physician rule therefore did not apply to that application. Instead, the administrative law judge had to explain how persuasive each medical opinion was and explain how the judge considered the opinion’s supportability and consistency with the record.

The court found that the administrative law judge did not satisfy those requirements. For Dr. Barrick’s opinion, the administrative law judge assigned slight weight but did not explain its supportability or consistency. For Dr. Wootan’s opinion, the administrative law judge discussed consistency but not supportability. For Dr. Meisel’s opinion, the administrative law judge discussed supportability but not consistency. The court held that this failure to follow 20 C.F.R. § 416.920c was legal error warranting remand.

Disposition

Judge Kevin Nathaniel Fox granted Quiles’s motion to remand the matter to the Commissioner for further administrative proceedings. The court denied the Commissioner’s motion for judgment on the pleadings. The ruling required further administrative consideration; it did not itself award Quiles disability insurance benefits or Supplemental Security Income.