Cintron v. Commissioner of Social Security

Background

Eliud Cintron sought review of the Commissioner of Social Security’s decision concerning his application for supplemental security income. The administrative law judge found that Cintron was not disabled from April 12, 2013, through October 23, 2016, but became disabled on October 24, 2016, when his age classification changed. The administrative law judge found that Cintron had adjustment disorder and osteoarthritis, and determined that he could perform sedentary work with a limitation to simple, routine, one- and two-step instructions and tasks.

The administrative law judge relied on the Medical-Vocational Guidelines, commonly called the “Grids,” to find that jobs existed in significant numbers before October 24, 2016. After that date, the administrative law judge found that no such jobs existed. Cintron challenged the use of the Grids, the treatment of medical-opinion evidence, and the evaluation of his statements about his symptoms. The parties filed cross-motions for judgment on the pleadings, asking the court to decide the case based on the pleadings and administrative record.

Use of the Medical-Vocational Guidelines

The court explained that the Grids may not be used alone when a claimant’s nonphysical limitations cause more than a negligible additional loss of work capacity. In that situation, the Commissioner generally must provide testimony from a vocational expert or similar evidence about available jobs.

The administrative law judge found that Cintron had mild limitations in understanding, remembering, or applying information and interacting with others, and moderate limitations in concentrating, persisting, or maintaining pace and adapting or managing himself. The court held that these limitations would almost certainly cause more than a negligible loss of work capacity beyond the limits of sedentary work. The administrative law judge’s statement that the limitations had little or no effect on unskilled sedentary work was conclusory and did not adequately explain why vocational-expert testimony was unnecessary.

The court directed the administrative law judge on remand to obtain vocational-expert testimony to determine whether Cintron’s nonphysical limitations prevented him from finding work before he turned 50.

Medical-Opinion Evidence

Because Cintron’s claim was filed before March 27, 2017, the older regulations, including the treating-physician rule, applied. That rule generally required an administrative law judge to give controlling weight to a treating physician’s opinion when it was well supported and consistent with the record. If the opinion was not given controlling weight, the administrative law judge had to consider specified factors, including the length and nature of the treatment relationship, supporting evidence, consistency with the record, and the physician’s specialization.

The administrative law judge gave only partial or limited weight to opinions from treating psychiatrists Dr. Han and Dr. Iloh. The court found that the administrative law judge did not explicitly apply the required factors when discounting those opinions. The court also questioned the reliance on cursory or isolated normal mental-status notes and the greater weight given to opinions from a nonexamining psychologist and a consulting examiner. It directed the administrative law judge to give appropriate deference to the treating physicians’ opinions and evaluate them under the applicable regulations.

Cintron’s Statements About His Symptoms

The court could not determine whether the administrative law judge properly evaluated Cintron’s statements about the intensity, persistence, and limiting effects of his symptoms. The administrative law judge referred generally to some statements made to treatment providers but did not identify specifically which statements had been rejected or cite Cintron’s filings or earlier testimony. The court therefore could not assess whether this part of the decision was proper.

Disposition

Judge Sarah Netburn granted Cintron’s motion and denied the Commissioner’s motion. The action was remanded to the Social Security Administration for a calculation of benefits or further proceedings consistent with the opinion. The court directed that proceedings before an administrative law judge be completed within 120 days; if no decision issued by then, a calculation of benefits was required immediately. The Clerk of Court was directed to terminate the motions at ECF Nos. 23 and 28.