Julie W. v. Kijakazi

Background

Julie W. applied for Disability Insurance Benefits in February 2021, alleging disability beginning June 30, 2020. The application was denied initially and on reconsideration. After a hearing at which Julie W. testified with an attorney and a vocational expert also testified, Administrative Law Judge Mark Solomon denied the application on April 7, 2022. The Appeals Council denied review on March 8, 2023, making the administrative law judge’s decision the Commissioner’s final decision.

The administrative law judge found severe impairments consisting of lumbar and cervical degenerative disc disease, lumbar radiculopathy, and obesity. He found that Julie W. had the residual functional capacity—the ability to perform sustained work despite her impairments—to perform sedentary work with limits on sitting, standing, walking, lifting, carrying, and certain postural activities. He concluded that she could perform her past relevant work as a user support analyst and therefore was not disabled during the relevant period.

Julie W.’s Arguments

Julie W. moved for judgment on the pleadings, asking the court to reverse the administrative law judge’s decision. She argued that the step-two analysis improperly treated her right-shoulder and mental impairments as non-severe, that the residual-functional-capacity finding was too broad, and that the administrative law judge improperly evaluated her subjective complaints about pain and other limitations.

Court’s Analysis

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

As to the shoulder impairments, the court found no reversible error. The record included normal shoulder X-rays, examinations showing full range of motion and strength, and medical opinions supporting sedentary, light, or unrestricted work. The court also concluded that the administrative law judge reasonably declined to add a reaching restriction to the residual functional capacity.

The court likewise found no reversible error in treating the mental impairments as non-severe. The administrative law judge found no limitation in four areas of mental functioning, and the court cited generally unremarkable mental-status examinations, Julie W.’s daily activities, and medical opinions indicating that her psychiatric impairments did not significantly interfere with basic work activities. The court also found a sufficient basis to conclude that the administrative law judge considered the non-severe impairments when determining the residual functional capacity.

Regarding the residual functional capacity, the court found substantial evidence supporting the finding that Julie W. could perform a reduced range of sedentary work. The court upheld the administrative law judge’s decision not to fully accept Dr. Aquiar’s more restrictive opinion because it was inconsistent with other medical opinions, treatment records, and Dr. Aquiar’s own examination findings.

Finally, the court upheld the evaluation of Julie W.’s subjective complaints. The administrative law judge accepted that her medically determinable impairments could produce her symptoms but found that the alleged intensity and limiting effects were not entirely consistent with the record. The court found support for that assessment in the clinical findings, conservative treatment, medical opinions, and daily activities such as household chores, shopping, managing money, and using public transportation.

Disposition

Judge Gary R. Jones denied Julie W.’s Motion for Judgment on the Pleadings. The case was dismissed, and the clerk was directed to enter final judgment in favor of the Commissioner and close the file.