Linval v. Commissioner of Social Security

Background

Angela Linval sought Disability Insurance Benefits and Supplemental Security Income under the Social Security Act. The administrative law judge found that she was disabled beginning May 31, 2020, but not disabled before that date. The judge found several severe impairments, including lumbar spine degenerative disc disease, a condition following a stroke, diabetes, and obesity, but classified her bilateral carpal tunnel syndrome as non-severe. The judge determined that Linval could perform light work with certain postural limits and could perform other jobs existing in significant numbers before May 31, 2020.

Linval challenged the decision based on the treatment of her carpal tunnel syndrome. She argued that the condition should have been classified as severe and that the judge should have included limits on using her hands and fingers in the assessment of her residual functional capacity, meaning what she could still do despite her medical conditions. The Commissioner argued that the decision was supported by substantial evidence and that any error was harmless.

Court’s Analysis

The court found that the administrative law judge’s finding that carpal tunnel syndrome was non-severe was not supported by substantial evidence. First, the judge relied on a November 2018 nerve-conduction study as a normal study of the upper extremities. The court determined that the study was actually of the lower extremities. Because the judge repeatedly relied on that study in evaluating the severity of Linval’s hand condition and the medical opinions, the error was not harmless.

Second, the judge relied on a May 2014 opinion stating that Linval had no upper-extremity limitations. The court found that the opinion was several years old and did not account for later evidence, including a diagnosis of bilateral carpal tunnel syndrome and examinations showing hand tenderness, tingling, decreased strength, and decreased sensation.

Third, the court found that the judge selectively relied on Linval’s daily activities without addressing her reported limitations. Linval reported difficulty lifting, doing her children’s hair, cleaning, washing dishes, cooking, doing laundry, and completing other tasks without help. She also reported frequent hand cramping and difficulty grabbing and picking up objects.

Fourth, the court identified medical evidence that the judge did not adequately address. That evidence included positive Tinel’s and Phalen’s tests, decreased grip strength, decreased sensation, worsening numbness and tingling, hand swelling, pain, weakness, and difficulty grasping objects. The court concluded that the total evidence required reconsideration of whether the carpal tunnel syndrome imposed more than a minimal limitation.

The court also found that the residual-functional-capacity analysis did not discuss Linval’s carpal tunnel syndrome or any hand and finger manipulation limits. An administrative law judge must consider both severe and non-severe impairments when assessing residual functional capacity. The court could not conclude that applying the correct legal standards would produce only one possible result because the record contained conflicting evidence about Linval’s diagnosis, symptoms, limitations, and daily activities.

Disposition

The court granted Linval’s motion for judgment on the pleadings, denied the Commissioner’s cross-motion for judgment on the pleadings, and remanded the case under sentence four of 42 U.S.C. § 405(g) for further administrative proceedings. The court directed that the severity of Linval’s carpal tunnel syndrome and the effect of any resulting limitations on her residual functional capacity be reevaluated. The Clerk was asked to terminate the pending motions and close the case.