Mason v. Commissioner of Social Security

Background

Kia Shonika Mason brought this action under Section 205(g) of the Social Security Act, challenging the Commissioner of Social Security’s final decision denying her applications for Disability Insurance Benefits and Supplemental Security Income. Mason alleged disability beginning October 9, 2017, based primarily on lumbar spine problems, radiating leg pain, and related limitations.

After a hearing, Administrative Law Judge Kieran McCormack found that Mason had severe degenerative disc disease and disc bulges of the lumbar spine, along with obesity. He determined that she had the residual functional capacity—the most she could still do despite her impairments—to perform sedentary work with additional postural restrictions and no operation of foot controls with her dominant leg. The Administrative Law Judge found that Mason could not perform her past work but could perform other jobs identified by a vocational expert, including food and beverage order clerk, semiconductor bonder, and surveillance system monitor. The Appeals Council denied review, making the Administrative Law Judge’s decision the Commissioner’s final decision.

Arguments and Medical Evidence

Mason argued that the Administrative Law Judge improperly evaluated the medical opinions and inadequately assessed her subjective complaints, leading to a residual-functional-capacity finding unsupported by substantial evidence. The Commissioner argued that the decision was supported by substantial evidence.

Dr. Julia Kaci, a consultative examiner, diagnosed chronic lower back pain and radiculopathy and described Mason as having “moderate” limitations with prolonged sitting, standing, walking, kneeling, squatting, lifting, carrying, pushing, and pulling. The Administrative Law Judge found Dr. Kaci’s opinion persuasive. Dr. L. Marasigan opined that Mason could sit for about six hours in an eight-hour workday, but the Administrative Law Judge found unpersuasive Dr. Marasigan’s opinion that Mason could perform medium work and specifically discussed only the persuasiveness of Dr. Marasigan’s postural limitations. Dr. Jennifer Ringstad provided opinions stating that Mason could sit for one hour in an eight-hour day in December 2017 and four hours in an eight-hour day in February 2019; the Administrative Law Judge found those opinions unpersuasive.

Court’s Analysis

The court held that the residual-functional-capacity finding was not supported by substantial evidence. A “moderate” limitation in sitting did not, by itself, translate into a specific number of hours. The Administrative Law Judge therefore needed to explain why Mason could nevertheless perform sedentary work, which generally requires sitting for about six hours during an eight-hour workday.

The court found that Dr. Kaci’s opinion did not adequately support the six-hour sitting conclusion because her examination also recorded limited lumbar movement, positive straight-leg raising in Mason’s right leg, decreased sensation in that leg, and imaging showing degenerative changes. The court further found that the Administrative Law Judge did not explain how he evaluated Dr. Marasigan’s sitting limitation and did not base the residual-functional-capacity finding on that limitation. After discounting the other medical opinions, the remaining evidence consisted largely of raw medical findings that the Administrative Law Judge was not qualified to interpret without appropriate medical guidance.

The court did not decide whether Mason was ultimately disabled or whether she was entitled to benefits. It held that the Commissioner’s decision could not stand because the sitting limitation was inadequately supported and remanded for further administrative proceedings. On remand, the Administrative Law Judge must reconsider whether Mason could sit for the time required for sedentary work and may develop the record further as appropriate.

Disposition

The court granted Mason’s motion for judgment on the pleadings, denied the Commissioner’s cross-motion, and remanded the case for further proceedings consistent with the opinion and order. The Clerk was requested to enter judgment.