Barrie A.L. v. Saul

Background

Barrie A.L. applied for Disability Insurance Benefits in June 2018, alleging that she became unable to work on April 1, 2017. The Social Security Administration denied the application initially and on reconsideration. After a hearing, Administrative Law Judge Jason Mastrangelo denied the application on November 21, 2019. The Appeals Council denied review, making the Administrative Law Judge’s decision the Commissioner’s final decision.

The Administrative Law Judge found that Barrie A.L. had severe impairments including osteoarthritis of the hips, inflammatory arthritis, fibromyalgia, obesity, and conditions following lumbar and cervical spinal fusions. He determined that she had the residual functional capacity—her remaining ability to work despite her medical limitations—to perform sedentary work with additional restrictions. He concluded that she could perform her past relevant work as an audit clerk and therefore was not disabled during the period addressed in the decision.

Barrie A.L., represented by counsel, moved for judgment on the pleadings, asking the court to rule in her favor based on the administrative record. The Commissioner filed a cross-motion for judgment on the pleadings.

The Court’s Analysis

The court reviewed whether the Commissioner applied the correct legal standards and whether substantial evidence supported the decision. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

Medical opinion evidence. The court concluded that the Administrative Law Judge did not properly evaluate the opinion of Dr. Suleman Bhana, Barrie A.L.’s treating rheumatologist. Dr. Bhana had treated her quarterly since March 2016 and reported chronic pain, limited finger movement, muscle aches, and stiffness. He opined that her pain was severe enough to interfere with attention and concentration 21 to 30 percent of the time.

The Administrative Law Judge found Dr. Bhana’s opinion unpersuasive, reasoning that it appeared to reflect a temporary symptom flare, conflicted with treatment notes showing improvement, and was inconsistent with daily activities and examinations showing intact concentration. The court found that the Administrative Law Judge improperly speculated that the opinion was based on a one-week flare, even though Dr. Bhana stated that the impairments lasted, or were expected to last, at least 12 months. The court also found that the decision did not explain or cite evidence supporting its conclusion that the treatment record showed improvement inconsistent with Dr. Bhana’s opinion. The court noted that the record contained extensive documentation of persistent pain and limitations.

The court found that Barrie A.L.’s limited seasonal work as a tax preparer did not sufficiently support rejecting Dr. Bhana’s opinion because the work was below substantial gainful activity, lasted for limited periods, and involved significant absences. The court did not find error in the Administrative Law Judge’s treatment of Dr. Samir Sodha’s opinion, which concerned reaching, fingering, and handling limitations. The court agreed that Dr. Sodha’s assessment was unsupported by the treatment record and inconsistent with Barrie A.L.’s testimony and electrodiagnostic testing.

Vision impairment. The court found that the decision did not adequately address Barrie A.L.’s reported loss of peripheral vision, episodes of blurred vision, reduced reading vision, and fatigue while reading. Although the Administrative Law Judge considered these complaints in formulating the residual functional capacity, the decision did not show adequate consideration of how blurred vision could affect the reading responsibilities of her past work as an audit clerk. The court directed that this issue be examined more thoroughly on remand.

Statements about pain and limitations. The Administrative Law Judge found that Barrie A.L.’s medically determinable impairments could reasonably be expected to cause her symptoms but decided that her statements about the intensity, persistence, and effects of those symptoms were not entirely credible. The court concluded that this assessment needed to be reconsidered because it was affected by the failure to properly evaluate Dr. Bhana’s opinion.

The court also found that the Administrative Law Judge listed Barrie A.L.’s daily activities without explaining the circumstances in which she performed them or how they translated into the ability to perform audit-clerk work. The court noted evidence that she performed only limited household tasks, received substantial help from her husband and foster son, needed help putting on socks, and sometimes could not do anything because of pain. The court directed the Administrative Law Judge to reconsider her statements while accounting for Dr. Bhana’s opinion and the context of her daily activities.

Disposition

The court held that remand for further administrative proceedings was necessary to reassess Dr. Bhana’s opinion, reconsider the effect of Barrie A.L.’s vision problems on her ability to perform past relevant work, and reassess her statements about pain and limitations.

Judge Gary R. Jones granted Barrie A.L.’s Motion for Judgment on the Pleadings, denied the Commissioner’s Motion for Judgment on the Pleadings, and remanded the case for further proceedings consistent with the Decision and Order. The clerk was directed to enter final judgment and close the file.