Arroyo v. Commissioner of Social Security

Background

Arianna Clarissa Arroyo applied for Title XVI Supplemental Security Income, alleging disability beginning January 27, 2018, because of bipolar disorder, depression, and cognitive issues. The claim was denied. After a hearing, Administrative Law Judge Michael J. Stacchini found that Arroyo had severe bipolar disorder and anxiety, but that these impairments did not meet or equal a listed impairment. The administrative judge determined that Arroyo could perform a full range of work with limits to simple, routine, repetitive tasks, regularly scheduled breaks, simple decision-making and workplace changes, and occasional interaction with the public, coworkers, and supervisors.

Arroyo had no past relevant work, but the administrative judge found that she could perform jobs such as packager, cleaner, and auto detailer. He therefore found her not disabled. The Appeals Council denied review, making that decision the Commissioner’s final decision. The parties then filed cross-motions for judgment on the pleadings.

Court’s Analysis

The court reviewed whether the Commissioner’s decision was supported by substantial evidence and whether the correct legal standards were applied. Under the regulations governing claims filed after March 27, 2017, an administrative law judge must explain how persuasive each medical opinion is, including by addressing the opinion’s supportability and consistency. Supportability concerns the medical evidence and explanations offered by the medical source. Consistency concerns how the opinion compares with evidence from other medical and nonmedical sources.

Psychologist Melissa Antiaris performed a consultative examination of Arroyo. Antiaris reported mildly impaired attention and concentration, mildly impaired memory, and below-average cognitive functioning. She also recorded Arroyo’s reports of worthlessness, crying spells, hopelessness, concentration difficulties, frequent panic attacks, and difficulty functioning independently. Antiaris diagnosed unspecified bipolar disorder and generalized anxiety disorder. She assessed marked limitations in regulating emotions, controlling behavior, and maintaining well-being; moderate limitations in using reason and judgment for work-related decisions; and several mild limitations involving complex instructions, interactions, concentration, pace, routine, and attendance.

The administrative judge found Antiaris’s opinions about marked limitations unpersuasive. He relied on findings such as Arroyo’s euthymic mood, appropriate eye contact, appropriate relating, and treatment notes describing stability without impulsive outbursts while taking medication. The court held that the administrative judge improperly selected favorable findings without explaining why those findings outweighed Antiaris’s other findings. The court also found that he selectively relied on treatment notes describing stability while failing to address references in the same records to frequent panic attacks, anger-control issues after Arroyo stopped taking medication, and occasional suicidal thoughts.

Because the administrative judge did not adequately evaluate the medical opinion evidence, the court could not meaningfully review the decision. It concluded that the decision was not supported by substantial evidence.

Disposition

The court granted Arroyo’s Motion for Judgment on the Pleadings, denied the Commissioner’s Cross-Motion for Judgment on the Pleadings, and remanded the case for further proceedings under 42 U.S.C. § 405(g). The opinion did not award benefits; it required further proceedings concerning the administrative decision.