Ingrid T.G. v. Commissioner of Social Security

Background

Ingrid T.G. applied for Disability Insurance Benefits in May 2017, alleging that she became disabled on September 3, 2016. The Social Security Administration denied the application initially and on reconsideration. After a hearing, Administrative Law Judge Katherine Edgell denied the claim on May 6, 2019. The Appeals Council denied review, making the administrative judge’s decision the Commissioner’s final decision.

The administrative judge found that Ingrid T.G. had severe anxiety disorder, obsessive-compulsive disorder, hypochondriasis, depression, bipolar or schizoaffective disorders, anemia, spinal conditions, fibromyalgia, chronic fatigue syndrome, and thyroid disease. The judge determined that she could perform light work with limits on lifting, bending, and interacting with others. Although she could not return to her past work, the judge found that other jobs existed in significant numbers that she could perform.

Motions and Issue

Ingrid T.G. brought this action seeking review under 42 U.S.C. §§ 405(g) and 1383(c)(3). Both sides moved for judgment on the pleadings, which asks the court to decide the case based on the pleadings and administrative record. Ingrid T.G. argued that the administrative judge improperly evaluated the medical opinion evidence.

Court’s Analysis

The court explained that, under the regulations applicable to this claim, the administrative judge had to assess each medical opinion’s persuasiveness, focusing particularly on supportability and consistency. The administrative judge had discounted the opinions of four treating providers—Dr. Stacey Gross, Dr. Rachel Moster, Dr. Heidi Fusco, and Dr. Phyllis Kwok—and had found the opinions of consultative examiners Dr. Catherine Pelczar-Wissner and Dr. Melissa Antiaris, along with non-examining State Agency physician Dr. C. Anderson, more persuasive.

The court held that the administrative judge’s evaluation was not supported by substantial evidence and was not consistent with applicable law. The court emphasized that fibromyalgia can cause disabling symptoms even when physical examinations show normal muscle strength and no neurological deficits. It likewise explained that somatic symptom disorder, by its nature, may not have an objective medical cause, so the absence of abnormal test results cannot alone disprove disabling symptoms.

The administrative judge also relied on Ingrid T.G.’s cooperation during appointments and ability to perform basic daily activities. The court held that these facts did not, without more, undermine the treating providers’ opinions that her pain and phobias could prevent sustained attention, attendance, and appropriate behavior under workplace stress.

The court further found that the administrative judge did not adequately consider the value of opinions from providers who had observed and treated Ingrid T.G. over time. Dr. Gross had treated her as needed since 2013, while some of the opinions the administrative judge found persuasive came from physicians who had examined her only once or had never examined her. The administrative judge also considered the medical opinions separately instead of addressing their consistency with one another, including the treating providers’ shared view that workplace stress would significantly affect Ingrid T.G.’s ability to function.

Disposition

Judge Gary R. Jones granted Ingrid T.G.’s motion for judgment on the pleadings, denied the Commissioner’s motion for judgment on the pleadings, and remanded the case for calculation of benefits. The court found that the record was complete and contained persuasive proof of disabling pain and phobias, so it found no purpose in additional administrative proceedings. The Clerk was directed to close the case and enter final judgment without prejudice to a timely application for attorneys’ fees and costs.