Parker v. Commissioner of Social Security

Background

Travis Parker sought review under the Social Security Act of the Commissioner of Social Security’s decision denying his application for Social Security Disability Insurance benefits. Parker alleged that he became disabled after a 2016 work-related injury involving his right shoulder. The opinion states that he had obesity, degenerative disc disease, carpal tunnel syndrome, vestibular dysfunction, shoulder tendinopathy, and a detached anterior superior labrum. He had undergone two right-shoulder surgeries and received treatment for shoulder, neck, and back symptoms.

An administrative law judge denied Parker’s application on October 28, 2019, and the Appeals Council later denied review. The administrative law judge found that Parker had severe impairments but that they did not meet the regulatory requirements for automatic disability. She determined that Parker had the residual functional capacity (RFC)—the most he could still do despite his impairments—to perform light work with additional restrictions. Those restrictions included limits on lifting, climbing, balancing, stooping, kneeling, crouching, crawling, reaching, pushing, pulling, handling, fingering, and feeling. Based on testimony from a vocational expert, the administrative law judge found that Parker could perform jobs such as housekeeper, inspector, and sales clerk.

Parker’s Argument

Parker’s only argument was that the administrative law judge had failed to properly evaluate the medical-opinion evidence when formulating the RFC. He argued that the opinions of Dr. Cheryl Archbald and Dr. Ronald Mann did not provide substantial evidence—relevant evidence that a reasonable person could accept as adequate—to support the RFC.

Court’s Analysis

The court found that the administrative law judge had fully and completely developed the record and had applied the correct legal standards. It concluded that the RFC determination was supported by substantial evidence in the record.

The court cited medical findings showing, among other things, normal strength, normal grip strength, normal gait and station, intact sensation, and generally moderate or stable findings. It also relied on opinions from Dr. Mann, Dr. Archbald, and state-agency reviewer Dr. Gary Ehlert that supported the ability to perform light work or work with related restrictions. The court explained that an RFC is an administrative determination for the administrative law judge, and it does not have to match any single medical opinion exactly if it is consistent with the record as a whole.

The court rejected Parker’s reliance on more restrictive opinions from Dr. Marc Habif and Dr. Jeffrey Salkin. It found those opinions insufficiently supported by the overall record, including later or conflicting evidence concerning Parker’s ability to lift, walk, and perform daily activities. The court also noted that statements describing Parker as “disabled” under New York workers’ compensation standards were not binding in the Social Security case because the two programs use different definitions of disability.

The court stated that it could not reweigh the evidence or independently decide whether Parker was disabled. Because the administrative law judge’s decision was supported by substantial evidence and used the correct legal standards, the court found no basis to disturb it.

Disposition

The court DENIED Plaintiff’s motion for judgment on the pleadings and GRANTED Defendant’s motion for judgment on the pleadings. The opinion therefore left in place the Commissioner’s decision that Parker was not disabled during the relevant period.