Garcia v. Commissioner of Social Security

Background

Laura A. Garcia applied for disability benefits under Titles II and XVI, alleging that her disability began on July 30, 2014. Her application was denied, and after hearings and review by the Appeals Council, Administrative Law Judge Mark Solomon again found that she was not disabled. The Appeals Council denied further review, making the administrative law judge’s decision the Commissioner’s final decision.

The administrative law judge found that Garcia had one severe impairment, major depressive disorder. He determined that she could perform medium work with limitations to simple work and concluded that she could perform her past work on a poultry production line.

Garcia’s treating primary-care physician, Dr. Emilio Perez, treated her at least sixteen times over five years and reported significant mental limitations, including problems with memory, concentration, following instructions, maintaining a work routine, handling stress, and completing a normal workday. Other doctors also evaluated Garcia for mental-health and physical conditions, but Dr. Aurelio Salon, who examined her once, was the only physician who did not agree that depression caused work-related limitations.

Court’s Analysis

Because Garcia filed her claim before March 27, 2017, the treating-physician rule applied. Under that rule, an administrative law judge generally must give controlling weight to a treating physician’s opinion when it is well supported and not inconsistent with substantial evidence. If the judge gives the opinion less weight, the judge must provide good reasons and consider factors such as the length, frequency, nature, and extent of the treatment relationship, supporting medical evidence, consistency with the record, and the doctor’s specialty.

The court found that the administrative law judge improperly discounted Dr. Perez’s opinions. The judge characterized Perez’s treatment notes as inconsistent with his conclusions and noted that Perez was not a psychiatrist. The court concluded that these reasons were inadequate because the administrative law judge did not properly consider Perez’s repeated treatment of Garcia, the nature and extent of that relationship, or contemporaneous treatment notes supporting Perez’s opinions.

The court also found that the administrative law judge did not adequately explain why he gave substantial weight to Dr. Salon’s opinion despite Salon’s one-time examination. Under the treating-physician rule, the court stated, Salon’s opinion should have received limited weight rather than substantial weight.

Ruling

The court held that the administrative law judge failed to properly apply the treating-physician rule and did not support the disability decision with substantial evidence. The court therefore granted Garcia’s Motion for Judgment on the Pleadings, denied the Commissioner’s Cross Motion for Judgment on the Pleadings, and remanded the case under 42 U.S.C. § 405(g) for further administrative review, including a new hearing and decision. Judge Ona T. Wang signed the Opinion and Order on March 24, 2023.