KUNKEL v. COMMISSIONER OF SOCIAL SECURITY
3:22-cv-03279
D.N.J.Mar 11, 2025Background
- Plaintiff Emily K. sought Disability Insurance Benefits and Supplemental Security Income, alleging disability from various physical (e.g., fibromyalgia, ankle injuries) and mental impairments (e.g., PTSD, depression) since June 1, 2018 (later amended to February 2, 2018).
- Plaintiff’s claims were denied initially and on reconsideration; an administrative hearing before an ALJ likewise resulted in a denial, which became final when the Appeals Council declined review.
- The ALJ found Plaintiff had severe impairments but retained the residual functional capacity (RFC) to perform a limited range of sedentary work and could do other jobs in the national economy.
- Plaintiff argued on appeal that the ALJ erred at steps three and four of the five-step sequential evaluation, especially for rejecting the functional limitations assessed by her treating physician, Dr. Jamie Rygielski, regarding her ability to sit, stand/walk, and attend work regularly.
- The Court found the ALJ inadequately explained why Dr. Rygielski’s opinion was unpersuasive, particularly regarding supportability and consistency, and may have overstated Plaintiff’s daily activities.
- The district court reversed the Commissioner’s decision and remanded the case for further proceedings, directing clearer analysis of medical opinions, Plaintiff’s functional limitations, and the effects of assistive devices and obesity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ properly evaluate Dr. Rygielski’s opinion and Plaintiff’s RFC? | ALJ failed to identify specific inconsistencies and overstated Plaintiff’s daily activities; ALJ ignored unique aspects of fibromyalgia and supportability of limitations. | ALJ correctly applied standards, thoroughly considered the record, and cited inconsistencies with treatment notes and daily activities. | ALJ’s reasoning was inadequate; remand required for better explanation of supportability/consistency and factual basis. |
| Was the rejection of Dr. Rygielski’s opinion supported by substantial evidence? | No, because ALJ cited no record evidence and misstated Plaintiff's activities; failed to address fibromyalgia properly. | ALJ highlighted lack of support and inconsistencies with other medical evidence and daily activities. | Not supported; ALJ did not give adequate reasons or cite evidence for rejecting treating physician’s limitations. |
| Did the ALJ properly address Plaintiff’s use of assistive devices/environmental limitations? | ALJ misunderstood the medical opinions and failed to consider the full impact and time-period of necessary devices. | ALJ reasonably found Plaintiff’s need for devices was not for a continuous 12-month period. | Remand required for clarification of medical evidence and proper evaluation of these limitations. |
| Should court affirm, reverse, or remand? | Reverse and grant benefits, or at least remand for proper weighing of evidence. | Affirm in full; ALJ’s findings were sufficiently reasoned and supported. | Reversed and remanded for further proceedings consistent with court’s opinion. |
Key Cases Cited
- Biestek v. Berryhill, 587 U.S. 97 (defines “substantial evidence” in administrative record review)
- Burnett v. Comm’r of Soc. Sec., 220 F.3d 112 (ALJ must give sufficient explanation of evidence rejected)
- Sykes v. Apfel, 228 F.3d 259 (standard for reviewing ALJ’s factual findings)
- Fargnoli v. Massanari, 247 F.3d 34 (substantial evidence standard is deferential but not a rubber stamp)
- Plummer v. Apfel, 186 F.3d 422 (ALJ must explain reasons for rejecting evidence and weigh credibility)
- Cotter v. Harris, 642 F.2d 700 (requires ALJ to identify evidence accepted/rejected for meaningful review)