Antonio L.M. v. Commissioner of Social Security

Background

Aramis Antonio L.M. applied for Supplemental Security Income benefits in November 2019, alleging that he had been disabled since January 31, 2018. The Social Security Administration denied the application initially and on reconsideration. After a hearing, Administrative Law Judge John Carlton denied the application on April 14, 2021. The Appeals Council denied review on January 31, 2022, making the administrative law judge’s decision the Commissioner’s final decision.

The administrative law judge found that Antonio had a severe depressive disorder with psychotic features, but that his impairments did not meet or equal a listed impairment. The judge found that Antonio could perform work at all physical exertion levels, subject to limits requiring simple, routine work without production-rate pacing, only occasional interaction with supervisors and coworkers, and no more than superficial interaction with the general public. Although Antonio could not perform his past work as a food sales clerk, the judge found that other jobs existed in significant numbers in the national economy that he could perform.

Antonio, represented by counsel, sought judicial review under 42 U.S.C. §§ 405(g) and 1383(c)(3). He moved for judgment on the pleadings under Rule 12(c), and the Commissioner filed a cross-motion for judgment on the pleadings.

Medical-opinion issue

Antonio argued that the administrative law judge improperly evaluated the medical-opinion evidence and therefore reached an unsupported residual functional capacity determination. The court explained that, under the regulations applicable to Antonio’s application, medical opinions are evaluated for their persuasiveness, including their supportability and consistency with the record.

The court upheld the administrative law judge’s decision to find Dr. Konstantinos Tsoubris’s opinion unpersuasive. Dr. Tsoubris had assessed, among other things, marked limitations in interacting with supervisors and maintaining regular attendance, an extreme limitation in regulating emotions and controlling behavior, and a marked limitation in maintaining personal hygiene and appropriate attire.

The court found that these severe limitations were inconsistent with examination findings showing that Antonio was cooperative, had fair social skills, coherent and goal-directed thoughts, intact memory, attention, and concentration, and fair insight and judgment. The court also relied on treatment records and reported activities showing generally good or great mood, improvement with therapy and treatment, symptom control with medication, time spent with friends and neighbors, exercise, shopping, and social activities. The court noted that the administrative law judge also considered opinions from state-agency physicians and included mental and social restrictions in the residual functional capacity finding rather than disregarding Antonio’s impairments entirely.

Symptom testimony

Antonio testified about paranoia, panic attacks, poor sleep, depression, auditory and visual hallucinations, anxiety, and social phobias. The administrative law judge found that his medically determinable impairments could reasonably cause the alleged symptoms but concluded that his statements about their intensity, persistence, and limiting effects were not fully credible.

The court held that this assessment was supported by substantial evidence and consistent with applicable law. The treatment record showed overall progress and generally effective symptom management. The court also found that the administrative law judge properly considered Antonio’s ability to manage personal care, prepare meals, perform simple chores, and spend time with others. The administrative law judge incorporated significant stress and social-interaction limits into the residual functional capacity finding.

Disposition

Judge Gary R. Jones concluded that substantial evidence supported the administrative law judge’s evaluation of the medical opinions, assessment of Antonio’s subjective complaints, and overall residual functional capacity determination. The court DENIED Antonio’s motion for judgment on the pleadings, GRANTED the Commissioner’s motion for judgment on the pleadings, and DISMISSED the case. The Clerk was directed to enter final judgment and close the file.