Aghadiuno v. Commissioner of Social Security

Background

Rita Ngozi Aghadiuno applied for Disability Insurance Benefits and Supplemental Security Income, alleging that she became disabled because of physical and mental conditions including posttraumatic stress disorder, anxiety, depression, chronic anemia, thyroid problems, Lyme disease, edema, deep vein thrombosis, and diabetes. She later amended her alleged onset date to November 1, 2017. The application was denied initially and after a hearing before Administrative Law Judge Kieran R. McCormack. The Appeals Council denied review, making the administrative law judge’s decision the final agency decision.

The administrative law judge found that Aghadiuno had severe impairments including hypothyroidism, lymphedema, Lyme disease, anemia, depressive disorder, anxiety disorder, and posttraumatic stress disorder. He found that she could perform light work, could not perform her past relevant work, but could perform other work existing in significant numbers. Aghadiuno challenged the decision, arguing that the administrative law judge inadequately evaluated medical opinions when determining her physical and mental residual functional capacity, meaning her ability to perform work activities on a sustained basis.

Court’s analysis

The court held that the administrative law judge did not support the physical residual-functional-capacity finding with substantial evidence. In particular, the administrative law judge did not adequately explain how Dr. Hang Kyu Park’s observations and diagnoses concerning swelling, edema, leg pain, and left shoulder, arm, and finger pain affected the decision. The court also found that the administrative law judge relied on daily-activity evidence without adequately addressing Aghadiuno’s statements that she needed assistance and frequent breaks. The court concluded that the administrative law judge improperly substituted his own interpretation of the medical evidence for competent medical opinions.

The court also found that Dr. Park’s opinions were consistent with other evidence documenting swelling and edema. It therefore held that the administrative law judge needed to reconsider those opinions and the other evidence when evaluating Aghadiuno’s physical residual functional capacity.

As to the mental residual functional capacity, the court found that the administrative law judge inadequately discounted part of Dr. Alison Murphy’s opinion that Aghadiuno had a moderate limitation in maintaining a regular schedule. The court said intact memory did not by itself resolve whether anxiety and other mental-health symptoms interfered with maintaining a schedule, and it noted evidence that Aghadiuno missed appointments because of anxiety and indecisiveness.

The court further found that the administrative law judge did not adequately evaluate the opinions of Gordon Weiss, a licensed clinical social worker. The court said Weiss’s opinions were consistent with other evidence of anxiety and depression, including reports by Nurse Practitioner Susan Baez and Dr. Murphy. It also held that giving Weiss’s opinions little consideration solely because he was a licensed clinical social worker was improper, because information from social workers can help explain how an impairment affects a claimant’s ability to work.

Disposition

The court granted Aghadiuno’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 or make a final determination that Aghadiuno was disabled; it required further agency proceedings to reconsider the physical and mental residual-functional-capacity analysis.