Roberts v. Saul

Background

James Roberts sought judicial review under Section 205(g) of the Social Security Act after the Social Security Administration denied his application for disability insurance benefits. Roberts applied for benefits for a disability period beginning June 13, 2017. After a hearing, Administrative Law Judge Paul W. Goodale found on October 29, 2019, that Roberts was not disabled. The Appeals Council affirmed, making the Commissioner’s denial final.

Roberts had worked as a foreman and marble setter for more than 30 years at Port Morris Tile. He was injured on June 13, 2017, when a truck tailgate came loose and a crate of marble fell onto him. The opinion describes fractures involving his pelvis, sacrum, ribs, and left elbow, along with later medical treatment for other conditions.

Administrative Decision

The administrative law judge used the Social Security Administration’s five-step disability process. He determined that Roberts did not have an impairment meeting or medically equaling a listed impairment. He found that Roberts could perform light work with several restrictions, including a sit-stand option, occasional climbing and postural activities, limits on exposure to certain air contaminants, and no assembly-line-type work. The administrative law judge relied on treatment records and opinions from several medical providers.

Roberts’s Arguments

Roberts argued that the administrative law judge:

Court’s Analysis

The court reviewed whether substantial evidence supported the Commissioner’s findings and whether the correct legal standards were applied. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion. The court explained that it could not decide anew whether Roberts was disabled.

Listing 1.04A

The court held that Roberts did not satisfy all the requirements of Listing 1.04A. The listing required evidence of nerve-root compression, limited spinal motion, motor loss accompanied by sensory or reflex loss, and—when the lower back is involved—positive straight-leg-raising tests in both sitting and lying positions.

The court agreed with the administrative law judge that Roberts lacked the required positive straight-leg-raising tests in both positions. The record contained several positive tests, but the opinion states that the tests by Dr. Douglas A. Schwartz showed positive results only in the sitting position. Other tests were negative or were confirmed only in the sitting position. Because Roberts failed to satisfy this requirement, the court concluded that he did not meet Listing 1.04A. The court said it therefore did not need to decide whether Roberts’s reported muscle strength of 4-/5 was enough to establish the required motor loss.

Other Impairments

The court agreed with the administrative law judge that Roberts’s acute pancreatitis was not a severe impairment. The court relied on the condition’s relative stability, the lack of reported abdominal symptoms at the alleged disability onset or hearing, and the absence of evidence that the condition caused work-related functional limitations.

The court also agreed that Roberts’s left elbow injury did not satisfy the requirement that a severe impairment last, or be expected to last, at least 12 months. The opinion notes evidence that the elbow had healed, that Roberts did not report continuing elbow pain at a later examination or at the hearing, and that other medical evidence did not show an ongoing disabling elbow condition.

The court further agreed that the right foot injury was not a severe impairment. By May 2018, Roberts had a normal gait, could walk on his heels and toes without difficulty, had full ankle movement, and had no sensory deficit or muscle atrophy. The court also found that the administrative law judge reasonably discounted contrary medical evidence because it was inconsistent with other medical opinions.

Pain and Other Symptoms

The court found that the administrative law judge properly considered Roberts’s efforts to obtain relief from pain and other symptoms under Social Security Ruling 16-3p. The administrative law judge considered the medical evidence, Roberts’s statements, his daily activities, travel, and medications. The court also noted that the administrative law judge accounted for residual symptoms from the accident by limiting Roberts to a range of light work with a sit-stand option.

Disposition

The Commissioner’s Motion for Judgment on the Pleadings was GRANTED, and Roberts’s Motion for Judgment on the Pleadings was DENIED. The court found no basis for remand.