Mercedes P. v. Commissioner of Social Security

Background

Mercedes P. applied for Supplemental Security Income benefits in April 2018, alleging that she had been disabled since August 22, 2016. The Social Security Administration denied her application initially and again on reconsideration. After a hearing at which Mercedes P. testified with an interpreter and a vocational expert testified, Administrative Law Judge Miriam Shire denied the application on July 26, 2019. The Appeals Council denied review on August 21, 2020, making the Administrative Law Judge’s decision the Commissioner’s final decision.

Mercedes P., represented by counsel, filed this federal action seeking judicial review under 42 U.S.C. §§ 405(g) and 1383(c)(3). Both sides filed motions for judgment on the pleadings, asking the court to rule based on the existing administrative record.

Administrative Decision

The Administrative Law Judge found that Mercedes P. had severe impairments, including fibromyalgia, right-sided carpal tunnel syndrome, benign positional vertigo, sleep apnea, headaches, and an affective disorder. The Administrative Law Judge found that none of these impairments, alone or together, met or medically equaled a listed impairment.

The Administrative Law Judge determined that Mercedes P. retained the residual functional capacity (RFC), meaning her remaining ability to work despite her impairments, to perform a reduced range of light work. The RFC included restrictions involving heights, dangerous machinery, driving, use of her right hand, climbing and other postural activities, use of a cane, job complexity, workplace changes, and breaks. The Administrative Law Judge found that Mercedes P. could not perform her past work as a fast-food worker but could perform other jobs existing in significant numbers in the national economy.

Arguments and Analysis

Mercedes P. raised two principal arguments. First, she contended that the Administrative Law Judge improperly discounted her statements about the intensity and limiting effects of her symptoms, particularly because fibromyalgia generally cannot be measured through laboratory tests or ordinary objective findings. Second, she argued that the RFC did not adequately account for limitations involving prolonged sitting and standing and use of her hands. She also argued that the hypothetical questions posed to the vocational expert did not include all of her limitations.

The court rejected these arguments. It explained that the Administrative Law Judge recognized fibromyalgia as a severe impairment and did not reject Mercedes P.’s symptoms solely because objective clinical signs were lacking. Instead, the Administrative Law Judge considered her activities of daily living, including caring for her daughter, performing light chores, and shopping; her generally conservative treatment; and the medical opinions in the record.

The court found substantial evidence supporting the Administrative Law Judge’s evaluation of Mercedes P.’s statements. It also found substantial evidence supporting the RFC, including opinions from consultative examiner Dr. Ann Marie Finegan and state-agency reviewing consultant Dr. A. Saeed, as well as the clinical findings, treatment record, and daily activities. The court noted that the RFC included restrictions addressing her right-hand carpal tunnel syndrome.

The court further explained that it must uphold an administrative finding when substantial evidence supports it, even if the record could also support a different conclusion. Because the court sustained the RFC, it rejected the related challenge to the vocational expert’s testimony.

Disposition

Magistrate Judge Gary R. Jones denied Mercedes P.’s motion for judgment on the pleadings, granted the Commissioner’s motion for judgment on the pleadings, and dismissed the case. The Clerk was directed to enter final judgment and close the file.