Maria Saunders v. Kilolo Kijakazi
6f4th1
| D.C. Cir. | 2021Background
- Maria Saunders slipped on ice at work on January 7, 2014, injuring her hip and back and did not return to work as a bus attendant for the D.C. school system.
- Saunders filed for Social Security disability benefits about six months after the fall and received numerous medical evaluations over the next three years, including from treating physicians Dr. Edwin Williams (primary care) and Dr. Joseph Liberman (neurologist).
- Saunders also obtained D.C. workers’ compensation benefits; her federal SSDI claim was denied on reconsideration and proceeded to an ALJ hearing in November 2017.
- The ALJ gave varying weight to several medical opinions, discounted treating opinions in whole or part, and expressly gave no weight to Dr. Liberman’s November 2017 opinion; the ALJ did not acknowledge Dr. Liberman’s December 2014 evaluation.
- A vocational expert testified the Dictionary of Occupational Titles lists a bus attendant as light work, although Saunders had performed it as heavy work; the ALJ concluded Saunders could perform her past work as generally performed (light work) and denied benefits.
- The District Court affirmed; the D.C. Circuit reversed and remanded because the ALJ failed to consider Dr. Liberman’s December 2014 treating opinion, which could establish a closed 12‑month period of disability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ failed to consider a treating physician’s medical opinion (Dr. Liberman Dec. 2014) | Saunders: ALJ ignored a relevant treating neurologist opinion showing chronic post‑traumatic pain and functional limits and thus erred. | Commissioner: The 2014 opinion was duplicative of the 2017 opinion, so omission was harmless. | Court: ALJ erred by not evaluating the 2014 opinion; it differed from 2017 and could establish a 12‑month closed period, so omission was prejudicial. |
| Whether ALJ properly weighed treating and examining opinions generally | Saunders: ALJ improperly discounted treating opinions without adequate reasons. | Commissioner: ALJ explained weight given to various examiners and agency consultants. | Court: Because ALJ failed to consider significant treating evidence, remand required for proper evaluation of all opinions. |
| Whether disability onset/12‑month duration was properly considered | Saunders: ALJ needed to consider whether there was at least a continuous 12‑month disabling period after the 2014 injury. | Commissioner: Evaluation of later opinions sufficed. | Court: Failure to consider the 2014 opinion prevented proper determination of a possible 12‑month closed period; remand required. |
| Whether ALJ correctly found claimant could perform past relevant work in national economy | Saunders: ALJ relied on vocational testimony that did not account for how she actually performed the job. | Commissioner: Job as generally performed is light work per DOT and VE. | Court: Declined to resolve on appeal because remand required for medical‑opinion errors; left for Commissioner to reassess. |
Key Cases Cited
- Butler v. Barnhart, 353 F.3d 992 (D.C. Cir. 2004) (standards for judicial review of SSA disability determinations and treating‑physician weight principles)
- Williams v. Shalala, 997 F.2d 1494 (D.C. Cir. 1993) (treating physician opinion must be given controlling weight if well supported and not inconsistent)
- Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (definition of substantial evidence standard)
- Shinseki v. Sanders, 556 U.S. 396 (U.S. 2009) (harmless‑error principle in administrative appeals)
- Jones v. Astrue, 647 F.3d 350 (D.C. Cir. 2011) (remand where ALJ rejected treating physician opinion without adequate explanation)
- Berry v. Astrue, 622 F.3d 1228 (9th Cir. 2010) (court may decline to address other claims where remand is required for a new hearing)
- Fla. Mun. Power Agency v. FERC, 315 F.3d 362 (D.C. Cir. 2003) (clarifying that substantial evidence is more than a scintilla)