Olga M. v. Kijakazi

Background

Olga M. applied for Disability Insurance Benefits and Supplemental Security Income in 2015, alleging that she became disabled on November 4, 2015. After an earlier court remand, Administrative Law Judge Michael Stacchini again denied her applications in February 2022. The judge found that Olga M. had several severe physical and mental impairments but retained the residual functional capacity—the most she could still do despite those impairments—to perform sedentary work with restrictions. The judge determined that she could not return to her past work but could perform other jobs existing in significant numbers.

Olga M. and the Commissioner each moved for judgment on the pleadings, asking the court to decide the case based on the administrative record. Olga M. argued that the administrative law judge improperly evaluated the medical opinions and therefore reached an unsupported residual-functional-capacity finding.

Court’s Analysis

The court concluded that the administrative law judge inadequately evaluated the medical evidence concerning neck movement and reaching. Treating neurologist Dr. Robert Fekete and treating pain-management physician Dr. Lyle Posecion both found significant limitations in Olga M.’s ability to move her neck and reach. Consultative examiner Dr. Julia Kaci also found moderate limitations involving neck movement and limitations that supported restricting lifting, carrying, pushing, and pulling.

Despite that evidence, the administrative law judge found that Olga M. could frequently rotate, flex, and extend her neck and perform frequent reaching. The court held that the administrative law judge did not sufficiently explain how those findings could be reconciled with the treating doctors’ opinions and the medical evidence documenting continuing pain and limitations despite extensive treatment. The court also found that the administrative law judge did not explain how much weight was given to Dr. Kaci’s assessment concerning reaching or adequately connect Olga M.’s daily activities to the ability to perform frequent reaching or neck movement throughout an eight-hour workday.

The court rejected Olga M.’s separate arguments concerning concentration, persistence, and pace, finding that the administrative law judge reasonably accounted for those issues by limiting her to simple, routine tasks with regular breaks. The court also found no reversible error concerning migraines. Although the administrative law judge did not list migraines as a medically determinable or severe impairment, the record showed that they were generally controlled with Botox injections, and the residual-functional-capacity restrictions addressed identified migraine triggers such as extreme cold and excessive noise.

Disposition

The court granted Olga M.’s motion for judgment on the pleadings, denied the Commissioner’s motion for judgment on the pleadings, and remanded the case for further administrative proceedings. The remand required a proper assessment of the evidence, particularly the treating physicians’ opinions about neck movement and reaching. The court directed that proceedings before the administrative law judge be completed within 120 days of the order and entered final judgment in favor of Olga M. The opinion does not state that benefits were awarded. The clerk was directed to close the file after entering judgment.