Lisandra A. v. Commissioner of Social Security

Background

Lisandra A. applied for Disability Insurance Benefits under the Social Security Act in October 2015, alleging that she became unable to work on May 19, 2015. The Social Security Administration denied the application initially and on reconsideration. After a hearing at which Lisandra A. testified with an attorney and a vocational expert also testified, Administrative Law Judge Deanna Sokolski denied the application.

Lisandra A. had amended her application to seek benefits for a closed period ending when she returned to work on December 1, 2017. The administrative judge found severe impairments including degenerative disc disease in the cervical and lumbar spine, cervical and upper-extremity radiculopathy, bilateral carpal tunnel syndrome, right shoulder impingement, bilateral knee osteoarthritis, and muscle strain. The administrative judge found that Lisandra A. could perform sedentary work with restrictions, could not return to her past relevant jobs, but could perform other jobs existing in significant numbers in the national economy. The Appeals Council declined review, making that decision the Commissioner’s final decision.

The parties filed competing motions for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). The court reviewed whether the Commissioner applied the correct legal standard and whether substantial evidence—relevant evidence that a reasonable person could accept as adequate—supported the decision.

Listings Analysis

Lisandra A. argued that her impairments met Listing 1.04(A), which concerns certain spinal disorders accompanied by nerve-root compression and specified neurological findings, including limitation of spinal motion, motor loss involving muscle weakness or atrophy, sensory or reflex loss, and, for lower-back involvement, positive straight-leg-raising tests.

The administrative judge stated that the imaging did not show nerve-root or spinal-cord compression. The court found that statement was incorrect. The record included cervical radiculopathy and an MRI showing a large C5-6 disc herniation causing compression of the spinal cord and moderate central spinal stenosis. But the court concluded that the error did not require remand because the record did not show the required muscle weakness or atrophy. Several examinations showed full strength and no atrophy, while other examinations showed only occasional slight reduction in strength. The court therefore held that the finding that Listing 1.04(A) was not satisfied was supported by substantial evidence.

Medical Opinion Evidence

Dr. Allen Meisel performed a consultative orthopedic examination and opined that Lisandra A. had marked limitations in standing, walking, climbing stairs, bending, and kneeling, and moderate limitations in lifting, carrying, and handling objects. The administrative judge gave the opinion partial weight, accepting the moderate lifting and carrying limitations but not the marked limitations.

The court upheld that assessment. The administrative judge reasonably found the marked limitations inconsistent with Dr. Meisel’s own examination findings, which included full strength, a normal gait, and the ability to rise from a chair without difficulty. The court also noted evidence that Lisandra A. generally had full or only slightly diminished strength, could walk without assistance, returned to work as a home health aide, and had a treating physician who restricted heavy lifting, carrying, and bending but did not identify restrictions on standing or walking. The court stated that resolving conflicts in the evidence was the Commissioner’s role and that the administrative judge’s decision was supported by substantial evidence.

Testimony About Pain and Limitations

Lisandra A. testified that pain from a 2015 work injury, particularly in her right shoulder, caused difficulty walking, sitting, reaching, personal hygiene, sweeping, and mopping. She also testified that she sometimes used a cane and returned to work after her workers’ compensation benefits ended even though her physical condition had not changed.

The administrative judge found that Lisandra A.’s impairments could reasonably cause her alleged symptoms but that her statements about their intensity and limiting effects were not fully consistent with the record. The court upheld that finding because treatment notes generally documented full or slightly diminished strength and the ability to walk without assistance. The court also found it reasonable to consider her return to work as a home health aide when assessing the extent of her claimed limitations. The court emphasized that the administrative judge did not disregard her pain but limited her to a reduced range of sedentary work.

Disposition

Judge Gary R. Jones ordered that Lisandra A.’s motion for judgment on the pleadings was denied. The Commissioner’s motion for judgment on the pleadings was granted. The clerk was directed to enter final judgment in favor of the Commissioner and close the case.