Arch v. Commissioner of Social Security

Background

Nicole Arch sought review of the Commissioner of Social Security’s decision denying her application for Supplemental Security Income. Arch alleged disability based on physical and mental conditions, including problems affecting her shoulder, neck, head, spine, headaches, mood, anxiety, sleep, and attention.

In a prior related proceeding, the court remanded Arch’s case because the administrative law judge had not sufficiently considered three opinions from Arch’s treating physician, Dr. Syed Hosain. After further proceedings, Administrative Law Judge Michael J. Stacchini again denied benefits on August 12, 2022. The administrative law judge found that Arch had twelve severe impairments but retained the residual functional capacity (RFC)—the ability to perform work-related activities despite her limitations—to perform restricted light work. Although she could not perform her past work, the administrative law judge found that she could perform other jobs existing in significant numbers in the national economy.

Arguments and Analysis

Arch challenged the decision on two grounds. First, she argued that the administrative law judge should have given controlling weight to Dr. Hosain’s opinions. Because Arch filed her application before March 27, 2017, the treating-physician rule applied. That rule generally requires an administrative law judge to give more weight to a treating source’s opinion and controlling weight when the opinion is well supported and consistent with the record.

The court held that the administrative law judge properly gave Dr. Hosain’s opinions little weight. The administrative law judge recognized Dr. Hosain’s long treatment relationship with Arch and his specialty in pain management, but found that his opinions lacked supporting objective examination findings. The administrative law judge also found that Dr. Hosain’s extreme physical and mental limitations conflicted with his treatment notes, which often described Arch as having no acute distress, intact strength and sensation, normal gait, and normal attention and concentration. The administrative law judge further found that the opinions conflicted with other evidence, including observations by Arch’s psychiatrist and reports that medication, stretching, muscle relaxers, physical therapy, and a lidocaine patch improved her symptoms.

Second, Arch argued that the RFC should have included a specific restriction for time off task or reduced concentration caused by cervicogenic and migraine headaches. The court found that the administrative law judge considered Arch’s headache testimony, medical records, treatment, medication response, and reports concerning her memory and concentration. Although the RFC did not contain a separate headache-related restriction, the court concluded that the RFC was supported by substantial evidence, meaning relevant evidence that a reasonable person could accept as adequate to support a conclusion. The court also found that Arch had not shown that an additional headache-related limitation was required.

Ruling

Judge Valerie Figueredo denied Arch’s motion for judgment on the pleadings and affirmed the Commissioner’s determination. The court directed the clerk to terminate the motion and terminate the case.