Reid v. Commissioner of Social Security

Background

Ashley Mae Reid sought judicial review of the Social Security Administration’s denial of her application for Supplemental Security Income under Title XVI of the Social Security Act. She alleged that major depressive disorder, attention deficit hyperactivity disorder, generalized anxiety disorder, memory problems, and intellectual limitations prevented her from working. She was represented by counsel at the administrative hearing.

The administrative law judge found that Reid had severe impairments consisting of major depressive disorder, attention deficit hyperactivity disorder, generalized anxiety disorder, and mild intellectual disorder. The judge found that her impairments did not meet or equal the listed requirements for disability, including Listing 12.05, which concerns intellectual disorder. The judge determined that Reid had the residual functional capacity (RFC)—her maximum ability to work despite her limitations—to perform work at all exertional levels, subject to limits requiring simple, routine, repetitive, low-stress work, no more than occasional workplace changes, and only occasional interaction with coworkers, supervisors, and the public. Based on testimony from a vocational expert, the judge found that Reid could perform jobs such as garment folder, bagger, and photocopy-machine operator.

Reid’s Arguments

Reid challenged the decision on two grounds. First, she argued that her intellectual impairments satisfied Listing 12.05 because of her low intelligence-quotient score and alleged severe limitations in adaptive functioning. Second, she argued that the administrative law judge improperly evaluated her RFC and failed to adequately consider the supportability and consistency of opinions from Jonci Berneche, Mildred Riley-Channer, and Dr. Todd Deneen.

The Commissioner argued that substantial evidence supported the administrative law judge’s decision. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion.

Court’s Analysis

The court rejected Reid’s Listing 12.05 argument. It noted that the administrative law judge did not dispute that Reid had a low intelligence-quotient score or that her intellectual disorder began before age 22. Instead, the judge found that Reid did not show the required deficits in adaptive functioning or the required extreme or marked limitations in the areas of understanding and applying information, interacting with others, concentrating and maintaining pace, or adapting and managing herself.

The court found substantial evidence supporting those findings. The administrative law judge considered Reid’s educational history, including her graduation from high school with an Individualized Education Program; treatment and examination records; her activities; her ability to travel between New York and Virginia; her socialization with family and friends; her personal care; her appropriate grooming and dress; and the largely conservative treatment consisting of medication management and counseling. The court concluded that the record supported the finding that Reid’s limitations were moderate rather than sufficiently severe to satisfy Listing 12.05.

The court also rejected Reid’s challenge to the RFC determination. It found that the administrative law judge addressed the supportability and consistency of the medical opinions. The judge compared Berneche’s and Riley-Channer’s opinions with treatment records describing normal or stable cognitive and mental-status findings. The judge also considered Dr. Deneen’s findings, including his assessment that Reid had no limitation in using reason and judgment for work-related decisions, no limitation in interacting appropriately with others, mild limitations in some areas, and moderate limitations in others. The court held that the administrative law judge reasonably evaluated these opinions together with the rest of the record.

The court emphasized that it could not replace the Commissioner’s fact-finding with its own. Because the evidence could reasonably support the administrative law judge’s interpretation, the court concluded that remand was not warranted.

Disposition

The court denied Reid’s motion for judgment on the pleadings. It directed the clerk to mark the motion at Docket Number 16 as denied and enter judgment for the Commissioner. The administrative denial of Reid’s Supplemental Security Income claim therefore remained in place.