Natal v. Saul

Background

George Natal, Jr. sought judicial review of the Social Security Administration’s final decision denying his application for Supplemental Security Income benefits. Natal alleged disability based on depression, stress, mental-health issues, high blood pressure, and anxiety. After a hearing, Administrative Law Judge Alexander Levine found that Natal was not disabled. The agency’s Appeals Council denied review, making the administrative law judge’s decision the Commissioner’s final decision.

The administrative law judge found that Natal had eight severe impairments: major depressive disorder; cannabis, cocaine, and alcohol use disorders; asthma; hypertension; left shoulder pain; and high cholesterol. The judge determined that Natal did not have an impairment meeting or equaling a listed impairment. The judge found that Natal could perform a restricted range of light work, including simple, routine tasks and only occasional interaction with the public, coworkers, and supervisors. Although Natal could not perform his past work as a furniture mover or sorter, the judge found that he could perform other jobs existing in significant numbers, including photocopy machine operator, marker, and produce weigher.

Issues

Natal challenged the administrative law judge’s residual functional capacity finding—the assessment of what work-related activities he could still perform. He argued that the judge improperly evaluated the medical opinions and failed to properly evaluate his subjective complaints and medication history.

Court’s analysis

The court applied the substantial-evidence standard, which asks whether the administrative record contains enough relevant evidence that a reasonable person could accept it as supporting the agency’s conclusion. The court held that the administrative law judge properly evaluated the medical opinions under the regulations applicable to Natal’s application.

The court found substantial evidence supporting the judge’s reliance on the opinions of Dr. Kahn and Dr. Flach, who found mild or moderate limitations in Natal’s ability to interact with others. The court also found that treatment records, Natal’s reports, and his testimony supported limiting him to occasional interaction with other people. The court concluded that the judge reasonably found the more restrictive opinions of Dr. Engelberg and Dr. Bouchard-Burns unpersuasive because other evidence, including Natal’s reported daily activities and social interactions, did not show limitations of that severity.

The court also upheld the evaluation of Natal’s symptoms. It noted evidence that Natal could perform household activities, travel by public transportation, visit family, go to parks and the library, and shop and drive even during an anxiety attack. The court further held that the administrative law judge was not required to discuss every item of evidence separately. It found that the record showed relatively mild symptoms or improvement even during periods when Natal did not take his medication consistently.

Disposition

The court held that the administrative law judge’s decision was supported by substantial evidence. Judge Valerie Figueredo denied Natal’s motion for judgment on the pleadings, granted the Commissioner’s cross-motion for judgment on the pleadings, and affirmed the administrative law judge’s decision. The opinion explains that Andrew Saul was named when the case began, but Kilolo Kijakazi was later substituted as the defendant after becoming Acting Commissioner.