Maldonado v. Social Security Administration
2:16-cv-00392
D.N.M.Apr 26, 2017Background
- Plaintiff Jesus J. Maldonado (born ~1992) applied for SSI in 2013 alleging lifelong mental impairments (learning disability, depression, ADHD, anxiety) and sought benefits; ALJ Weiss denied benefits and the Appeals Council declined review, making the ALJ decision final.
- ALJ found Plaintiff has multiple severe mental impairments but not a listing-level impairment, and formulated an RFC for simple work with limits: no production-rate pace, few changes, occasional interaction with supervisors/co-workers/public, and ability to concentrate for 2 hours at a time.
- Three psychological opinions were central: non‑examining reviewer Dr. Gucker (MRFCA, 2014) — ALJ gave great weight; consultative examiner Dr. Padilla (2010) — ALJ gave limited weight; consultative examiner Dr. Owen (2014) — ALJ gave significant weight but did not adopt every restriction.
- Plaintiff argued the ALJ misapplied those medical opinions (failed to account for Section I MRFCA limitations, improperly discounted Padilla, and inadequately explained deviations from Owen) and thus erred in the RFC and Step Five finding.
- The ALJ relied also on Plaintiff’s and his mother’s testimony, function reports, MMSE score (27) and vocational expert testimony identifying three jobs that do not require public interaction; the district court affirmed the ALJ as supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly credited Dr. Gucker (non‑examining MRFCA) | Gucker’s Section I moderate/marked limitations were unaddressed in Section III and not incorporated into RFC | Section III narrative adequately encompassed Section I limits (persistence/adaptation), and RFC reflected those limits | Court: ALJ permissibly gave great weight to Gucker; Section III addressed the Section I limitations and RFC was consistent or more restrictive |
| Whether ALJ permissibly discounted Dr. Padilla (2010 consultative exam) | Padilla’s marked/moderate limitations should have been given greater weight; age of report insufficient reason to discount | ALJ properly considered factors (age, consistency, updated evidence) and compared Padilla to more recent evidence (Dr. Owen, function reports, testimony) | Court: ALJ’s reasons (older report, inconsistency with later records/functional evidence) are supported by substantial evidence; limited weight proper |
| Whether ALJ adequately explained deviations from Dr. Owen (2014 consultative exam) | ALJ gave Owen significant weight but failed to explain why some marked/moderate limitations were not adopted in RFC, violating SSR 96‑8p | ALJ explained deviation by citing function reports and other record evidence showing better functioning; the ALJ did not need hyper‑specificity here | Court: Explanation sufficient; no reversible error — even if conflict existed it was justified by record evidence |
| Whether RFC and Step Five finding accounted for interpersonal limits | RFC’s “occasional” public interaction conflicts with a marked limitation to interact with public/co‑workers | ALJ limited Plaintiff to jobs with minimal/occasional interpersonal contact; VE identified jobs with little/no public contact | Court: Jobs cited (cleaner, polisher, dishwasher) comport with assessed interpersonal limits; Step Five supported |
Key Cases Cited
- Doyal v. Barnhart, 331 F.3d 758 (10th Cir. 2003) (appeals‑council denial makes ALJ decision final)
- Wall v. Astrue, 561 F.3d 1048 (10th Cir. 2009) (five‑step sequential evaluation explained)
- Vigil v. Colvin, 805 F.3d 1199 (10th Cir. 2015) (review standard: substantial evidence and correct legal standards; ALJ must explain weight given to medical opinions)
- Keyes‑Zachary v. Astrue, 695 F.3d 1156 (10th Cir. 2012) (ALJ must consider and discuss weight assigned to medical opinions)
- Smith v. Colvin, 821 F.3d 1264 (10th Cir. 2016) (RFC must reflect medical evidence; ALJ not required to adopt every opinion word‑for‑word)
- Oldham v. Astrue, 509 F.3d 1254 (10th Cir. 2007) (ALJ need not discuss every weighing factor if decision makes clear the weight and reasons)