Wells v. Social Security Administration

Background

Robert Wells brought this action under 42 U.S.C. § 405(g), which permits court review of a final Social Security decision. He sought review of the Commissioner’s denial of his application for Disability Insurance Benefits. Wells alleged that his disability began on September 5, 2018, after a stroke limited vision in his left eye.

An administrative law judge (ALJ) held a hearing on November 4, 2019. Wells testified about his vision problems, difficulty navigating outside his home, back cramping, mental-health effects, and other limitations. A vocational expert testified that a person with the limitations described by the ALJ could not perform Wells’s past work but could perform other jobs, including linen room attendant, office cleaner, and dining room attendant.

The ALJ found that Wells had severe impairments including left vision loss from retinal artery occlusion, depressive disorder, anxiety disorder, diverticulosis, mild emphysema and asthma, anemia, and chronic kidney disease. The ALJ determined that these impairments did not meet or equal a listed impairment. The ALJ assigned Wells a residual functional capacity—the most he could still do despite his impairments—that allowed all levels of physical work but included restrictions involving climbing, respiratory irritants, workplace hazards, driving, task complexity, workplace changes, interaction with others, depth perception, left-eye distance vision, and restroom access. The ALJ concluded that Wells could not perform his past relevant work but could adjust to other work existing in significant numbers in the national economy, and therefore was not disabled.

The Commissioner moved for judgment on the pleadings, asking the court to rule based on the administrative record. Wells did not file an opposition identifying errors in the ALJ’s decision. He submitted only a letter referring to a recent hospitalization and asking that the case be resolved without further delay.

Court’s review of the residual functional capacity

The court concluded that substantial evidence supported the ALJ’s residual-functional-capacity determination. Regarding Wells’s left-eye impairment, the court found that the ALJ reasonably restricted climbing, driving, exposure to workplace hazards, activities requiring depth perception, and far visual acuity with the left eye. The court stated that these limitations were consistent with medical opinions and other record evidence.

The court also found support for the restrictions addressing Wells’s mental impairments, including limits to simple tasks, few workplace changes, and no more than occasional interaction with the public, coworkers, and supervisors. The restrictions addressing asthma and mild emphysema were supported by the medical evidence, including normal spirometry and a notation that Wells was not experiencing shortness of breath. The court further noted that the record did not identify work-related restrictions caused by several other conditions, including hypertension and chronic kidney disease.

The court held that the ALJ had considered Wells’s impairments and had not significantly departed from any medical-source opinion in the record. Because the ALJ’s findings were supported by substantial evidence, the court gave them the required deference.

Court’s review of available work

The court also found substantial evidence supporting the ALJ’s conclusion that Wells could perform other work. The ALJ had asked the vocational expert about a worker who could not perform activities requiring depth perception, and the vocational expert identified several occupations with significant numbers of available jobs. The ALJ also confirmed that the identified jobs did not require depth perception.

The court considered objections Wells had previously raised about the identified occupations. It concluded that those objections did not undermine the vocational expert’s testimony. The court therefore determined that the ALJ’s finding about available work was supported by substantial evidence.

Disposition

Judge Gabriel W. Gorenstein granted the Commissioner’s motion for judgment on the pleadings. The court requested that the Clerk enter judgment. The opinion does not state that the action was dismissed with prejudice or without prejudice.