Harris v. Kijakazi

Background

Juanita M Harris sought judicial review under the Social Security Act of the Commissioner’s decision denying her disability insurance benefits. Harris alleged that she became disabled on December 14, 2017, when an airplane-door handle struck her face at work. She reported post-concussion syndrome, headaches, post-traumatic stress disorder, depression, anxiety, attention deficit disorder, and, beginning in June 2020, diabetes.

An administrative law judge first denied Harris’s claim in June 2020. The agency’s Appeals Council later sent the matter back for another hearing because much of the first hearing transcript was unavailable and the initial decision was internally inconsistent about one medical opinion. After a second hearing, the administrative law judge again found that Harris was not entitled to benefits.

The administrative law judge found that Harris had severe impairments but that they did not meet the agency’s listed-impairment criteria. He determined that Harris could perform work at any physical exertion level before her diabetes diagnosis, subject to restrictions such as low-stress work, simple and repetitive tasks, limited workplace changes, occasional interaction with others, and limits on noise, light, irritants, vehicles, machinery, and heights. Beginning with the diabetes diagnosis, he limited her to light work in addition to those restrictions. Although she could not return to her flight-attendant job, a vocational expert identified other jobs, including routing clerk and mailing clerk, that she could perform.

Harris’s Arguments

Harris argued that the residual functional capacity—the most work she could still perform despite her impairments—did not adequately account for her physical, psychological, psychiatric, and cognitive limitations. She challenged the administrative law judge’s treatment of medical opinions and argued that her cognitive difficulties prevented her from performing competitive, unskilled work.

Court’s Analysis

The court first concluded that Harris received a full and fair hearing and that the administrative law judge fully developed the administrative record. The court then reviewed whether the decision was supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as sufficient, and whether the correct legal standards were used.

As to physical limitations, the court found substantial evidence supporting the finding that Harris had no exertional limitations before June 30, 2020. The record generally showed normal range of motion, muscle strength, gait, station, and sensation, and agency consultants and Dr. Nina Spooner found no exertional limitations. The court also upheld the light-work limitation after Harris’s diabetes diagnosis, noting that later physical examinations were normal and that the record supported the administrative law judge’s assessment even though no medical opinion specifically stated what exertional capacity was appropriate after the diagnosis.

As to psychological and psychiatric limitations, the court held that the administrative law judge reasonably considered Harris’s reported symptoms and medical evidence. The court found that the administrative law judge reasonably declined to adopt Dr. Melissa Antiaris’s opinion that Harris had marked limitations in regulating emotions, controlling behavior, and maintaining well-being because that opinion conflicted with Dr. Antiaris’s examination findings and other generally unremarkable mental-status examinations. The court also concluded that the low-stress-work restrictions and limits on workplace interaction accounted for the supported psychiatric limitations.

As to cognitive limitations, the court rejected Harris’s argument that the administrative law judge failed to apply the standard for unskilled work. Because the administrative law judge relied on vocational-expert testimony rather than the Medical-Vocational Guidelines, the court found that the cited standard did not govern the decision. The court further held that the administrative law judge reasonably assessed mild limitations in understanding, remembering, and applying information and moderate limitations in concentration, persistence, and pace. The court found that the record, including several examinations showing average or intact cognitive functioning, supported the assessment and the restrictions to simple, repetitive, low-stress work.

Disposition

The court denied Harris’s motion for judgment on the pleadings and granted the Commissioner’s motion for judgment on the pleadings. The Clerk was directed to enter final judgment in favor of the Commissioner and close the case. Judge Katharine H. Parker therefore left the denial of Harris’s disability insurance benefits in place.