Sagrario M. v. Security
- Jones
- 1:20-cv-10027
- U.S. District Court · Southern District of New York
- 21
In Sagrario M. v. Commissioner of Social Security, Judge Jones denied benefits review, granted the Commissioner’s motion, and dismissed the case.
Sagrario M.’s applications for Disability Insurance Benefits and Supplemental Security Income benefits remained denied; the Commissioner’s decision was upheld, and the case was dismissed.
What happened
In Sagrario M. v. Commissioner of Social Security, Sagrario M. sought court review after the Social Security Administration denied her applications for disability insurance and supplemental security income benefits. An administrative law judge found that she had several serious medical conditions but could perform a limited range of sedentary work and other jobs existing in significant numbers.
Sagrario M. argued that the administrative law judge improperly evaluated medical opinions and discounted her reports about pain and limitations. The court concluded that the judge reasonably evaluated the conflicting medical evidence, relied on a medical expert’s testimony, and considered treatment records and Sagrario M.’s daily activities. The court found that the decision was supported by substantial evidence and followed the correct legal standards.
Judge Gary R. Jones denied Sagrario M.’s motion for judgment on the pleadings, granted the Commissioner’s motion for judgment on the pleadings, and dismissed the case. The clerk was directed to enter final judgment and close the case.
The detailed version
- Sagrario M. v. Security · No. 1:20-cv-10027
- Jones
- Apr. 27, 2022
Background
Sagrario M. applied for Disability Insurance Benefits and Supplemental Security Income benefits in January
- She alleged that she became disabled on November 18,
- The Social Security Administration denied her applications initially and again on reconsideration. After a hearing, Administrative Law Judge Seth I. Grossman denied the applications on October 11,
- The Appeals Council denied review on October 9, 2020, making the administrative law judge’s decision the Commissioner’s final decision.
The administrative law judge found severe impairments including carpal tunnel syndrome, bilateral rotator cuff tear syndrome, lumbar radiculopathy, obesity, diabetes, and diabetic retinopathy. He determined that Sagrario M. retained the residual functional capacity—the most she could still do despite her impairments—to perform sedentary work with several restrictions, including a five-minute standing option each hour, limited climbing and postural activities, limited overhead reaching, and frequent fingering and handling. He found that she could not perform her past work as a case manager or case worker, but that other jobs existed in significant numbers in the national economy that she could perform.
The parties filed competing motions for judgment on the pleadings, asking the court to decide the case based on the administrative record and their written arguments.
Medical-opinion argument
Sagrario M. argued that the administrative law judge improperly evaluated opinions from Dr. Cyrus Boquin and consultative examiner Dr. John Fkiaras. Dr. Boquin offered opinions involving substantial restrictions, including limits on sitting, standing, walking, lifting, changing positions, concentration, breaks, and attendance. Dr. Fkiaras identified several moderate to marked limitations involving walking, standing, sitting, lifting, carrying, reaching, bending, and other activities.
The court explained that, under the regulations applicable to Sagrario M.’s application, the administrative law judge had to evaluate the persuasiveness of medical opinions, particularly their supportability and consistency with the overall record. The administrative law judge found the opinions from Dr. Boquin and Dr. Fkiaras unpersuasive because he considered them inadequately supported and inconsistent with the record.
The court held that this analysis was supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate. The court noted that the administrative law judge relied in part on testimony from medical expert Dr. Albert Oguejifor, who reviewed the medical evidence and concluded that Sagrario M. could perform sedentary work with certain restrictions. The court also cited examination findings showing, among other things, normal joint range of motion, muscle strength, sensation, and reflexes in some examinations; full grip strength and hand and finger dexterity; full wrist and elbow range of motion; and no muscle atrophy. The court stated that resolving conflicts between medical opinions was the Commissioner’s responsibility when the decision was supported by substantial evidence.
Subjective-symptom argument
Sagrario M. also argued that the administrative law judge improperly discounted her reports about pain and functional limitations. She testified about lower-back and thigh pain, vision problems, carpal tunnel syndrome, shoulder problems, neuropathy, diabetes-related complications, balance problems, difficulty reaching and lifting, and limits on sitting, standing, and walking.
The administrative law judge found that Sagrario M.’s impairments could reasonably cause her symptoms but concluded that her statements about their intensity, persistence, and limiting effects were not fully consistent with the evidence. The court found that conclusion supported by substantial evidence and consistent with the law. It pointed to the treatment records, medical opinions, and Sagrario M.’s reported activities, including some self-care, simple household chores, shopping, and managing money. The court emphasized that the administrative law judge did not reject the existence of her pain or limitations; instead, he found that they limited her to a reduced range of sedentary work rather than preventing all work.
Disposition
Judge Gary R. Jones concluded that the Commissioner’s final decision was supported by substantial evidence and applied the correct legal standards. The court denied Sagrario M.’s motion for judgment on the pleadings, granted the Commissioner’s motion for judgment on the pleadings, and dismissed the case. The clerk was directed to enter final judgment and close the case.
Read the full 21-page opinion on CourtListener, the free public archive maintained by the Free Law Project.