Samantha R. L. v. Commissioner of Social Security

Background

Samantha R. L. applied for Disability Insurance Benefits in November 2019, alleging that she became disabled on April 19, 2019. The Social Security Administration denied the application initially and on reconsideration. After a hearing, Administrative Law Judge Kieran McCormack denied the claim on January 20, 2021. The Appeals Council later denied review, making the administrative law judge’s decision the Commissioner’s final decision.

The administrative law judge found that Samantha R. L. had several severe impairments, including attention deficit disorder, panic disorder, major depressive disorder, specific learning disorder, anxiety disorder, personality disorder, and impingement of both hips. He determined that she could perform a limited range of sedentary work, but could not return to her past work as a veterinary technician. Relying on vocational-expert testimony, he found that other jobs existed in significant numbers in the national economy and concluded that she was not disabled.

Issues and Analysis

The parties filed competing motions for judgment on the pleadings, asking the court to decide the case based on the existing administrative record. Samantha R. L. argued that the administrative law judge mishandled the medical-opinion evidence.

For claims filed after March 27, 2017, the applicable regulations require an administrative law judge to evaluate the persuasiveness of medical opinions, including their supportability and consistency. The court explained that although the former rule requiring controlling weight for certain treating-physician opinions no longer applied, a treating source’s opportunity to examine and treat a claimant remained important evidence, particularly in mental-health cases.

Dr. Audrey M. Walker reported that she had treated Samantha R. L. biweekly to monthly since 1998. Dr. Walker identified several mental-health diagnoses and stated that panic attacks, organizational problems, difficulty maintaining a regular schedule, and conflicts with supervisors and coworkers would interfere with Samantha’s ability to maintain work responsibilities. Dr. Walker opined that Samantha would be unable to maintain a work schedule. She provided a generally consistent second assessment in August 2020.

The administrative law judge found Dr. Walker’s opinions unpersuasive. The court concluded that he did not adequately account for Dr. Walker’s lengthy treating relationship. The court also found that the administrative law judge materially misstated the record by saying that Dr. Walker’s records did not show a mental-status examination. Both assessments stated that Dr. Walker had performed a psychiatric evaluation and included clinical findings about Samantha’s behavior, speech, thought processes, mood, affect, intellectual functioning, insight, and judgment.

The court stated that, if the administrative law judge believed the examinations were inadequately documented, he should have contacted Dr. Walker for more information before discounting her assessments. Although other medical evidence could support parts of the administrative law judge’s decision, the court found that the errors in applying the legal standard required a remand.

Disposition

Judge Gary R. Jones granted Samantha R. L.’s motion for judgment on the pleadings, denied the Commissioner’s motion for judgment on the pleadings, and remanded the matter for further proceedings. The remand requires application of the proper legal standard to the treating-source opinions and, if necessary, further development of the record by contacting Dr. Walker. The Clerk was directed to enter final judgment and close the file.