Hubbard v. Commissioner of Social Security

Background

Susan Ann Hubbard sought judicial review under 42 U.S.C. § 405(g) of the Social Security Administration’s denial of her application for disability insurance benefits. Her claimed disability period ran from October 11, 2011, through September 30, 2016, the date she was last insured. After an earlier round of this case resulted in a remand, Administrative Law Judge Michael Stacchini held another hearing and found on October 18, 2022, that Hubbard was not disabled. The Appeals Council did not review that decision, making it final.

The administrative law judge found severe impairments of left-knee osteoarthritis, lumbar strain, and obesity. He determined that Hubbard had the residual functional capacity (RFC), meaning her remaining ability to work despite her impairments, to perform sedentary work with restrictions: she could not climb ladders, ropes, or scaffolds, and could only occasionally climb ramps and stairs, balance, stoop, kneel, crouch, or crawl. The judge concluded that she could perform her past work as an accounting clerk.

Hubbard’s Arguments

Hubbard argued that the RFC was not supported by substantial evidence because the administrative law judge did not separately discuss every work-related function, including sitting, standing, walking, reaching, and fingering. She also argued that the judge gave too little weight to the opinion of her chiropractor, Maria Perri, who had treated her for several years and opined that Hubbard could not lift or carry more than five pounds or stand for two hours per day.

Hubbard separately argued that the administrative law judge failed to consider the effects of her obesity at the later stages of the disability analysis. The Commissioner responded that the RFC was supported by the medical evidence and that the decision adequately considered Hubbard’s weight.

Court’s Analysis

The court rejected Hubbard’s challenge to the RFC. It explained that an administrative law judge does not always have to provide a separate, explicit analysis of every possible work-related function. The relevant question is whether the judge applied the correct legal standards and whether substantial evidence—relevant evidence that a reasonable person could accept as adequate—supported the decision. The court found that the administrative law judge addressed the relevant limitations, considered Hubbard’s testimony and daily activities, relied on medical examinations and opinions, and explained why he found that she could perform a range of sedentary work.

The court also upheld the treatment of chiropractor Perri’s opinion. Under the regulations applicable to Hubbard’s claim, chiropractors were not classified as physicians or other acceptable medical sources whose opinions receive the special weight given to certain medical opinions. The administrative law judge therefore had discretion to assign the opinion little weight. The court found that he gave adequate reasons, including that the opinion lacked support from clinical findings and diagnostic testing and conflicted with Hubbard’s activities, course of treatment, and the consultative examiner’s opinion.

The court further concluded that the administrative law judge properly considered obesity. The judge identified obesity as a severe impairment, discussed medical evidence concerning Hubbard’s weight and physical limitations, considered her testimony about her weight loss and limitations, and incorporated postural restrictions into the RFC. The court therefore found no basis to conclude that obesity prevented Hubbard from performing her past work.

Disposition

The court agreed with the Commissioner on both issues. It denied Hubbard’s motion for judgment on the pleadings, directed the Clerk to enter judgment for the Commissioner, and directed the Clerk to close the case.