Jackson v. Commissioner Of Social Security
2:22-cv-01283-NJK
| D. Nev. | Feb 14, 2023Background:
- Plaintiff Mary Margaret Jackson applied for Title II disability insurance benefits on May 22, 2020, alleging disability beginning October 13, 2019; initial and reconsideration denials followed and the ALJ denied benefits on March 15, 2022; Appeals Council denied review.
- ALJ found Jackson met insured status through December 31, 2024, had severe impairments (spine disorders, anxiety, migraine, depression, trauma/stressor-related disorder), but no Listings-level impairment.
- ALJ assessed an RFC for light work with multiple postural limits, frequent overhead reaching, avoidance of certain environmental hazards, and a limitation to simple/unskilled tasks.
- At step 4 ALJ found Jackson could not perform her past manager job; at step 5 a vocational expert identified several jobs (mail clerk, small-products assembler, bench assembler) existing in significant numbers, so ALJ found not disabled through March 15, 2022.
- Plaintiff moved to reverse/remand, arguing the ALJ improperly evaluated medical opinions (Drs. Araza, Hendron, Short, Nelson and treating reviewers Ribeiro and Addonizio) and erred in step-five job findings; Commissioner cross-moved to affirm.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ evaluation of Drs. Araza & Hendron (prior administrative findings) | Araza/Hendron not analyzed for supportability/consistency; RFC fails to incorporate recommended detail | RFC materially accords with their findings; ALJ considered supportability/consistency and whole record | ALJ's consideration was supported by substantial evidence and RFC accords with their recommendations |
| ALJ treatment of Dr. Mark Short's opinion | ALJ inadequately explained why only part of Short's opinion was persuasive (esp. interpersonal limits) | ALJ properly found limitation to simple tasks persuasive and reasonably rejected inconsistent interpersonal findings | ALJ's partial persuasiveness finding supported; rejection of some interpersonal opinions reasonable due to internal inconsistency |
| ALJ treatment of Dr. Paul Nelson's opinion | ALJ misread Nelson and relied on mere recitation of data; other doctors should have addressed Nelson more fully | Nelson's form contains internal inconsistencies (medium-strength vs. limited standing/walking); ALJ properly found it unsupported by his exam | ALJ permissibly found Nelson unpersuasive for internal inconsistency and lack of exam support; related weighing of Ribeiro/Addonizio upheld |
| Step 5 job findings / GED reasoning level mismatch | RFC to "simple" work conflicts with inclusion of a GED Reasoning Level 3 job | Any over-inclusion is harmless because sufficient Level 2 jobs remain in significant numbers | Any inconsistency harmless; ALJ identified adequate alternate jobs consistent with RFC |
Key Cases Cited
- Bowen v. Yuckert, 482 U.S. 137 (recognizing the five-step disability evaluation framework)
- Webb v. Barnhart, 433 F.3d 683 (substantial-evidence standard on review)
- Biestek v. Berryhill, 139 S. Ct. 1148 (definition and low threshold for substantial evidence)
- Woods v. Kijakazi, 32 F.4th 785 (ALJ must address supportability and consistency for medical opinions)
- Shaibi v. Berryhill, 883 F.3d 1102 (when evidence allows multiple rational interpretations, court upholds ALJ)
- Rounds v. Comm’r of Soc. Sec., 807 F.3d 996 (ALJ responsible for translating medical opinions into RFC)
- Magallanes v. Bowen, 881 F.2d 747 (courts may draw reasonable inferences from ALJ findings)
- Tommasetti v. Astrue, 533 F.3d 1035 (harmless-error analysis when some jobs exceed RFC but others remain)