Young v. Saul

Background

Patricia Young sought review under Section 205(g) of the Social Security Act, 42 U.S.C. § 405(g), of the Commissioner’s final decision denying her applications for Disability Insurance Benefits and Supplemental Security Income. She alleged disability beginning November 30, 2016. An administrative law judge found that Young had severe physical and mental impairments but retained the residual functional capacity—the most she could still do despite her limitations—to perform light work with restrictions, including simple work. The judge found that Young could perform jobs existing in significant numbers in the national economy and therefore was not disabled.

The opinion states that Kilolo Kijakazi was substituted for Andrew Saul as Acting Commissioner after Kijakazi became Acting Commissioner on July 9, 2021. The case materials identify the matter as Young v. Saul, while the opinion’s caption names Kijakazi.

Arguments

Young did not challenge the administrative law judge’s findings about her physical impairments. Her arguments concerned her mental limitations. She contended that the judge failed to discuss the consistency among assessments by psychologist Daniel Cohen, treating physician Bruce H. Soloway, and treating therapist Lauren Fuchs. She also argued that the judge failed to evaluate the assessment by state-agency psychological consultant S. Junga.

The Commissioner argued that the administrative law judge’s decision was supported by substantial evidence. The administrative law judge had found the opinions of Cohen, Soloway, and Fuchs unpersuasive because they were insufficiently supported or inconsistent with treatment records, examination findings, other medical evidence, and Young’s reported activities. The judge had also relied on evidence including Young’s ability to babysit for several months and evidence that her anxiety improved with medication.

Court’s Analysis

The court held that the administrative law judge was not required to discuss consistency among the medical opinions in the way Young requested. The opinions were significantly inconsistent with one another in areas where they overlapped. The applicable regulations required the administrative law judge to assess each opinion’s supportability and consistency with the rest of the record, and the court found that the judge adequately explained those assessments.

The court agreed that the administrative law judge failed to acknowledge or assess S. Junga’s assessment as required by the regulations. The court nevertheless treated that error as harmless because considering the assessment would not reasonably have changed the result. Junga identified only mild or moderate limitations, concluded that Young could perform light work, and found that she was not disabled. The restrictions in Junga’s assessment were also accounted for by the administrative law judge’s limitation of Young to light, simple work.

Disposition

Judge Stewart D. Aaron found that the administrative law judge’s decision was free of legal error and supported by substantial evidence. The court denied Young’s motion for judgment on the pleadings and granted the Commissioner’s cross-motion for judgment on the pleadings. The Clerk of Court was requested to close the case.