Marcial v. Commissioner of Social Security

Background

Jasmin Aurea Marcial applied for Supplemental Security Income on May 26, 2017, alleging that she had been unable to work since January 1, 2014. The Social Security Administration initially denied the application. After a hearing at which Marcial and a vocational expert testified, the administrative law judge found that Marcial was not disabled. The Appeals Council declined to review that decision, making it the Commissioner’s final decision.

The administrative law judge found that Marcial had severe mood, bipolar, and seizure disorders but retained the capacity for light work with restrictions. Those restrictions included avoiding unprotected heights and hazardous machinery; not kneeling, crawling, or climbing certain equipment; performing repetitive work without high-volume or fast-paced production quotas; having only occasional close contact with supervisors and coworkers; and having no contact with the general public. The judge found that Marcial could perform jobs such as table worker and document preparer.

Marcial challenged the decision in federal court through a motion for judgment on the pleadings. She argued that the administrative law judge’s assessment of her residual functional capacity—the most she could still do despite her impairments—was not supported by substantial evidence. She also argued that the judge improperly evaluated medical opinions and her statements about her symptoms and limitations.

Medical-opinion evidence

The court upheld the administrative law judge’s treatment of nurse practitioner Teytelman’s opinion. Teytelman described Marcial as having extreme limitations in interacting with others, accepting instructions, responding to supervision, handling changes in routine, using public transportation, and performing other basic work-related mental activities.

The court agreed that those opinions were inconsistent with other evidence. The court cited records indicating that Marcial could perform activities of daily living, traveled by herself, occasionally socialized, and had normal mental-status findings. The court also relied on other opinions describing only mild limitations in memory, following simple instructions, interacting with others, and handling work stress. The court further noted that Teytelman’s treatment records indicated that Marcial could benefit from medication, which she had received, making the extreme limitations less consistent with the record.

Marcial’s statements about her limitations

The court also upheld the administrative law judge’s evaluation of Marcial’s subjective statements. The judge had explained that her statements were inconsistent with the medical evidence and evidence concerning her daily activities.

The court noted that Marcial had reported to evaluators that she could dress, bathe, groom herself, do chores, socialize, use public transportation, and listen to music. Those reports conflicted with statements at the hearing that she did not socialize, use public transportation, or do chores. The court also noted an inconsistency concerning whether Marcial could wash her hair. Based on these conflicts, the court found that the administrative law judge gave sufficient reasons for discounting her statements.

Disposition

The court concluded that the Commissioner’s decision was supported by substantial evidence and that the correct legal standards were applied. Marcial’s motion for judgment on the pleadings was DENIED, and the Commissioner’s motion was GRANTED. The court directed the Clerk to terminate the pending motions, remove the case from the court’s list of Social Security appeals, and close the case.