Sara A.H. v. Commissioner Of Social Security Of The United States

Background

Sara A.H. applied for Disability Insurance Benefits and Supplemental Security Income on November 5, 2020. She alleged that her disability began on May 12, 2018. The Commissioner denied the applications initially and again on reconsideration. After a hearing at which Sara A.H. testified with an attorney and a vocational expert also testified, Administrative Law Judge Michael Stacchini denied the applications on January 6, 2022.

The Administrative Law Judge found that Sara A.H. had several severe impairments, including polycystic ovarian syndrome, a congenital heart defect, asthma, cardiac arrhythmia, Chiari malformation, degenerative disc disease, migraines, hearing loss, obesity, and irritable bowel syndrome. He determined that she could perform light work with restrictions, including restroom access during regular breaks and for up to 5% of the work period. He found that she could not return to her past work as a stock clerk but could perform other jobs existing in significant numbers in the national economy. The Appeals Council denied review on May 19, 2023, making the Administrative Law Judge’s decision the Commissioner’s final decision.

Issue and Arguments

Sara A.H. asked the district court for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). She argued that the specific restroom restriction was not adequately explained or supported by substantial evidence. She relied on precedent cautioning that highly specific work restrictions must be based on the record rather than on an Administrative Law Judge’s unsupported assumption.

Court’s Analysis

The court reviewed whether the Commissioner applied the correct legal standard and whether substantial evidence supported the decision. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

The court held that the restroom restriction was supported by substantial evidence. Sara A.H. testified that she used the restroom about five times during a full day. Her records described diarrhea as mild and stress-related, and her gastrointestinal treatment records did not show severe cramping, frequent bathroom use, or difficulty with exertional activities. Her daily activities included personal care, preparing simple meals, household chores, and regular exercise.

The court also considered the medical opinions. A consultative examiner recognized her irritable bowel syndrome but identified no gastrointestinal-related work restrictions. State agency reviewers likewise did not identify work restrictions arising from that condition. Her treating gastroenterologist, Dr. Svetlana Korenfeld, offered a more restrictive opinion, including difficulties with sitting, standing, lifting, carrying, and frequent bathroom use, as well as a need to lie down during the day. The Administrative Law Judge found that opinion unpersuasive, and the court concluded that substantial evidence supported that assessment.

Although the 5% restroom restriction was not directly taken from a particular medical opinion, the court found that the Administrative Law Judge reasonably interpreted and reconciled the record. The court also noted that the restriction was arguably more favorable to Sara A.H. than the medical and opinion evidence otherwise supported.

Disposition

Judge Gary R. Jones denied Sara A.H.’s Motion for Judgment on the Pleadings. The court sustained the Commissioner’s denial of benefits and dismissed the case. The clerk was directed to enter final judgment in favor of the Commissioner and close the file.