Cruz v. Commissioner of Social Security

Background

Diana Cruz brought the action for A.E.T. under 42 U.S.C. § 405(g), challenging the Commissioner’s denial of A.E.T.’s application for child Supplemental Security Income benefits. A.E.T. had been diagnosed with attention-deficit/hyperactivity disorder, oppositional defiant disorder or disruptive behavior disorder, and insulin-dependent diabetes mellitus. An administrative law judge found those conditions to be severe but concluded that they did not meet, medically equal, or functionally equal an impairment listed in the Social Security regulations.

For children, functional equivalence is evaluated through six areas: acquiring and using information; attending and completing tasks; interacting and relating with others; moving about and manipulating objects; caring for oneself; and health and physical well-being. A child is considered disabled under this test if the child has marked limitations in two areas or an extreme limitation in one area.

Issues and arguments

Cruz argued that the administrative law judge should have found marked limitations in four areas: acquiring and using information, attending and completing tasks, interacting and relating with others, and caring for oneself. She pointed to evidence concerning A.E.T.’s academic difficulties, behavior, communication, diabetes management, absences, and reported difficulty with daily activities.

The Commissioner argued that the administrative law judge’s findings were supported by substantial evidence. That standard asks whether the record contains relevant evidence that a reasonable person could accept as adequate to support the decision.

Court’s analysis

The court reviewed each challenged area. In acquiring and using information, it relied on medical opinions finding less-than-marked limitations, A.E.T.’s fourth-grade report card, her individualized education plan, her reading and comprehension abilities, and her reported activities. The court acknowledged contrary evidence but explained that the administrative law judge was responsible for resolving conflicts in the record.

In attending and completing tasks, the court cited treatment records, medical opinions, A.E.T.’s reported ability to focus and complete homework, an examination finding a normal attention span for her age, school records, and her promotion to fifth grade. The court rejected the argument that the administrative law judge had to discuss every piece of evidence individually.

In interacting and relating with others, the court relied on opinions describing less-than-marked limitations, findings that A.E.T. interacted appropriately, school records describing friendships and sociability, hearing testimony about playing with friends, and treatment records showing improvement after treatment. In caring for oneself, the court relied on medical opinions, evidence that A.E.T. could perform several personal-care activities, and her testimony that she cleaned her room. The court also noted that the administrative law judge considered A.E.T.’s diabetes-management difficulties and school absences.

Disposition

The court concluded that substantial evidence supported the administrative law judge’s findings of less-than-marked limitations in all four challenged areas. It therefore concluded that the determination that A.E.T. was not disabled under the Social Security Act was supported by substantial evidence.

The report and recommendation recommended denying Cruz’s motion for judgment on the pleadings and granting the Commissioner’s cross-motion. The order text states that Cruz’s motion was denied, the Commissioner’s cross-motion was granted, and judgment was to be entered for the Commissioner. The opinion also directed the Clerk of Court to terminate Documents 16 and 18. It stated that the parties had 14 days after receiving the report and recommendation to file objections.