Morales v. Commissioner of Social Security

Background

Rose Morales sought Supplemental Security Income under Title XVI of the Social Security Act. She alleged that depression, post-traumatic stress disorder, anxiety, headaches, sleep problems, and related symptoms prevented her from working. An administrative law judge denied her application after a hearing, and the Social Security Appeals Council made that decision final. Morales then asked the district court to reverse the decision and find that she was disabled.

The administrative law judge found that Morales had severe impairments of depression and post-traumatic stress disorder, but that her migraine condition was not severe. The judge found mild limitations in understanding, remembering, and applying information and in adapting and managing herself, as well as moderate limitations in interacting with others and maintaining concentration, persistence, or pace. The judge determined that Morales could not perform her past work but retained the capacity to perform work at all exertional levels if it involved simple, routine tasks that were not performed at a production pace, only occasional interaction with supervisors and coworkers, and no interaction with the public. Based on vocational-expert testimony, the judge found that hand-packer, hospital-cleaner, and housekeeping-cleaner jobs existed in significant numbers in the national economy.

Morales’s Arguments

Morales argued that the administrative law judge incorrectly treated her education as at least a high-school education even though she had completed only the ninth grade. The court concluded that education was not a controlling factor in the decision and that the record supported the identified unskilled jobs regardless of whether her education was treated as ninth-grade or high-school level.

Morales also argued that the administrative law judge improperly selected favorable portions of the medical record while disregarding evidence that she needed to work in isolation. The court found that the judge reasonably relied on repeated mental-status examinations showing generally normal concentration, orientation, speech, and memory, with some depressed, anxious, or irritable moods. The court also noted evidence that Morales attended group therapy, went grocery shopping with her roommate, and used public transportation when necessary. In the court’s view, this evidence supported the limitations included in the residual functional capacity assessment.

Finally, Morales argued that the administrative law judge improperly relied on the fact that she identified her hearing companion as her uncle even though the judge believed he was her boyfriend, Edwin Cruz. The court found no evidence that this inconsistency affected the residual functional capacity determination. It concluded that the judge instead relied on Morales’s daily activities, the routine or conservative nature of her treatment, the absence of supported medical opinions finding her disabled, and the generally normal mental-status examinations.

Ruling

Judge Andrew L. Carter, Jr. held that the Commissioner’s decision was supported by substantial evidence and applied the correct legal standards. The court granted the Commissioner’s motion for judgment on the pleadings and denied Morales’s motion for judgment on the pleadings. It denied Morales’s requests for remand based on her education, the weighing of the medical evidence, the alleged need for isolation at work, and the alleged reliance on an improper factor. The Clerk of Court was directed to terminate the pending motions and close the case.