Matos v. Commissioner of Social Security

Background

Jose Matos sought review under Title XVI of the Social Security Act of an administrative law judge’s December 26, 2019 decision denying his disability benefits. Both Matos and the Commissioner of Social Security moved for judgment on the pleadings, which asks the court to decide the case based on the parties’ written filings.

The case had been referred to Magistrate Judge Jennifer E. Willis. She recommended granting Matos’s motion, denying the Commissioner’s motion, and remanding the case under sentence four of 42 U.S.C. § 405(g) for further proceedings. Neither party filed timely objections. The district court therefore reviewed the recommendation for clear error and found none.

Reasons for the Decision

The court agreed that the administrative law judge improperly handled Dr. Fassler’s opinion. Dr. Fassler identified moderate limitations in Matos’s mental abilities and limitations in sustained concentration and persistence, but also concluded that Matos could perform the basic mental demands of competitive, unskilled work on a sustained basis. The court found this opinion inherently contradictory and held that the administrative law judge failed to reconcile the conflict.

The court also found that the administrative law judge did not adequately address how Matos’s moderate limitations in completing a normal workday affected his ability to remain employed. The vocational expert testified that being absent more than once per month, arriving more than 30 minutes late more than once per month, or being off task more than 10 percent of the time would prevent competitive employment. The administrative law judge did not explain how someone with the limitations identified by Dr. Fassler could sustain work under those conditions.

The court agreed that the administrative law judge appropriately gave little weight to the opinions of Matos’s treating psychiatrists, Dr. Sagerman and Dr. Schwartz, because those opinions were inconsistent with medical records showing no more than moderate limitations. But the court found that the administrative law judge improperly rejected, without adequate explanation, Dr. Engelberg Damari’s findings of significant limitations in maintaining a regular schedule, learning new tasks, performing complex tasks independently, relating adequately to others, and dealing appropriately with stress. The court concluded that these errors meant the decision was not supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate support for the decision.

Ruling

Judge Daniels adopted the Report and Recommendation in full. Matos’s motion for judgment on the pleadings was granted. The Commissioner’s motion for judgment on the pleadings was denied. The administrative law judge’s decision was reversed, and the matter was remanded under sentence four of 42 U.S.C. § 405(g) for further proceedings consistent with the opinion. The decision does not state that benefits were awarded.