Ruiz v. Commissioner of Social Security
- Gabriel Gorenstein
- 1:20-cv-07638
- U.S. District Court · Southern District of New York
- 18
In Ruiz v. Commissioner of Social Security, Judge Gorenstein upheld the denial of disability benefits, rejecting Ruiz’s challenges to the administrative decision.
Lourdes Ruiz’s claim for Disability Insurance Benefits was denied, and the Commissioner’s decision was upheld.
What happened
Lourdes Ruiz sought disability insurance benefits, alleging that physical and mental impairments prevented her from working. An administrative law judge found that she could not return to her past work but could perform other light work available in the national economy, and therefore denied her claim.
Ruiz challenged that decision on two grounds. She argued that the judge had improperly evaluated whether her mental impairments met the criteria for serious, persistent disorders and had adopted a work-capacity finding without adequate medical support, including by rejecting a doctor’s opinion about her physical limitations and need for a cane.
Judge Gorenstein rejected both arguments. He concluded that substantial evidence supported the findings that Ruiz did not meet the relevant mental-disorder criteria and could perform limited light work. The court denied Ruiz’s motion for judgment on the pleadings and granted the Commissioner’s cross-motion.
The detailed version
- Ruiz v. Commissioner of Social Security · No. 1:20-cv-07638
- Gabriel Gorenstein
- Sept. 6, 2022
Background
Lourdes Ruiz sought judicial review under 42 U.S.C. §§ 405(g) and 1383(c) of the Commissioner of Social Security’s denial of her application for Disability Insurance Benefits. She alleged disability beginning October 28, 2015. After a hearing, the administrative law judge (ALJ) found that Ruiz had cervical and lumbar strain, major depressive disorder with psychotic features, and post-traumatic stress disorder, but was not disabled through December 31, 2018, the date she was last insured.
The ALJ found that Ruiz could not perform her past relevant work but retained the residual functional capacity (RFC)—her remaining ability to work despite her impairments—to perform light work with occasional overhead reaching, simple routine tasks, no work with the public, and only casual and occasional contact with coworkers. The ALJ found that jobs existed in significant numbers in the national economy that Ruiz could perform.
Both parties moved for judgment on the pleadings, asking the court to decide the case based on the existing administrative record.
Ruiz’s Arguments
Ruiz argued first that the ALJ failed to properly evaluate the paragraph C criteria for Listings 12.04 and 12.15. Those criteria apply to serious and persistent mental disorders and require, among other things, ongoing treatment or support and minimal ability to adapt to changes or increased demands. Medical expert Dr. Richard Cohen testified that Ruiz met the paragraph C criteria, but the ALJ concluded that she did not.
Ruiz argued that the ALJ’s explanation was too brief and improperly relied on her ability to drive, volunteer, and perform daily activities. The court acknowledged that the ALJ could have explained the term “function” in greater detail, but found that the ALJ had provided additional reasoning elsewhere in the decision. The record showed that Ruiz could drive, use public transportation, volunteer, shop, prepare meals, clean, do laundry, manage money, and handle other daily activities independently. The ALJ also found Dr. Kushner’s opinion more persuasive than Dr. Cohen’s opinion.
Ruiz’s second argument challenged the RFC determination. She claimed that the ALJ improperly relied on an assessment by a state agency single decision maker and rejected Dr. Ravi’s opinion, which was the only medical opinion addressing her physical limitations. Dr. Ravi had found moderate limitations in several physical activities and stated that Ruiz needed a cane to stand.
Court’s Analysis
The court held that the ALJ’s paragraph C determination was supported by substantial evidence. Although the ALJ initially stated the conclusion without much explanation, the ALJ later explained why Dr. Cohen’s opinion was not persuasive on that issue. The court found that Ruiz’s ability to function independently, together with the medical evidence and Dr. Kushner’s opinion, supported the conclusion that she did not meet Listings 12.04 or 12.15 through the paragraph C criteria.
The court also found no error concerning the state agency single decision maker because the ALJ never mentioned or relied on that assessment. The court further held that the RFC was supported by substantial evidence even though the ALJ did not credit Dr. Ravi’s opinion as a whole. Treatment records generally showed full strength in Ruiz’s arms and legs, mild limitations in neck and back movement, mild discomfort with straight-leg raising, and no other neurological deficits.
The court determined that Dr. Ravi’s moderate limitations were generally consistent with light work. As to the cane, the court found that Dr. Ravi’s statement was unexplained and inconsistent with his own finding that Ruiz had full strength. Other records described Ruiz’s gait as steady and often did not mention a cane or other assistive device. The court therefore concluded that substantial evidence supported the ALJ’s decision not to include a cane requirement in the RFC.
Disposition
Judge Gabriel W. Gorenstein denied Ruiz’s motion for judgment on the pleadings and granted the Commissioner’s cross-motion for judgment on the pleadings.
Read the full 18-page opinion on CourtListener, the free public archive maintained by the Free Law Project.