Koza v. Commissioner of Social Security

Background

Christopher Robert Koza sought review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying his applications for Social Security Disability Insurance Benefits, Supplemental Security Income, and Social Security Child’s Insurance Benefits. The Social Security Administration initially denied the applications. After a hearing, an administrative law judge (ALJ) denied the claims, and the Appeals Council denied Koza’s request for review.

The ALJ found that Koza had severe impairments including obstructive sleep apnea, autism spectrum disorder, attention-deficit hyperactivity disorder, a learning disorder, post-traumatic stress disorder, bipolar disorder, anxiety disorder, and disruptive mood dysregulation disorder. The ALJ found that these impairments did not meet or equal the required regulatory listings.

The ALJ determined that Koza had the residual functional capacity (RFC)—the most he could still do despite his impairments—to perform a full range of work at all exertional levels, subject to these restrictions: he could not climb ropes, ladders, or scaffolds; had to avoid unprotected heights and hazardous machinery; could perform only simple, routine, repetitive work-related tasks; and could have only occasional contact with the public, coworkers, and supervisors. Because Koza had no past relevant work, the ALJ relied on vocational-expert testimony that a person with this RFC could perform jobs such as hand packager, cleaner, and dining-room attendant.

Arguments

Koza raised one challenge. He argued that the ALJ improperly formulated the RFC by failing to explain why the RFC did not expressly include two moderate limitations identified by Alison Murphy, Ph.D. Dr. Murphy found moderate limitations in sustaining an ordinary routine and regular attendance at work, and in regulating emotions, controlling behavior, and maintaining well-being. The ALJ had described Dr. Murphy’s opinion as persuasive.

The Commissioner sought judgment on the pleadings, a decision based on the parties’ written submissions when no material factual dispute requires a trial. The court reviewed whether the Commissioner’s decision was supported by substantial evidence—relevant evidence that a reasonable person could accept as adequate—and whether the correct legal standards were applied.

Analysis

The court held that the two moderate limitations did not necessarily require additional restrictions in the RFC. Regarding routine and attendance, the court concluded that restrictions to simple, routine work and limited interaction can account for moderate limitations in maintaining a schedule or regular routine. Such a limitation did not necessarily mean that Koza could not work consistently at any job.

Regarding emotional regulation, behavior, and well-being, the court concluded that these moderate limitations did not identify a specific physical or mental work restriction that the ALJ had to state separately. The court found that the ALJ could account for them through the RFC’s restriction to only occasional contact with the public, coworkers, and supervisors.

Disposition

The court found that Koza had not shown that the RFC lacked substantial evidentiary support. It denied Koza’s motion for judgment on the pleadings and granted the Commissioner’s cross-motion for judgment on the pleadings. The court requested that the Clerk enter judgment.