(SS) Taylor v. Commissioner of Social Security, 1:22-cv-00215-BAM

Background

Plaintiff Sandy Monique Taylor applied for SSI on April 6, 2017, alleging congenital heart disease (tetralogy of Fallot with pulmonary atresia), pacemaker/ICD, ventricular tachycardia, palpitations, fatigue, left-ear hearing loss, headaches, obesity, and mood/anxiety symptoms.
ALJ Duane D. Young held a hearing (Nov. 22, 2019); Plaintiff testified about daily chest pain, tachycardia episodes, lightheadedness, limited walking/standing/sitting tolerance, and difficulty concentrating in class.
ALJ found severe impairments related to Plaintiff’s cardiac condition, obesity, and left-ear hearing loss, but concluded Plaintiff did not meet or equal Listings 4.02/4.05/4.06 and that her mental impairments were nonsevere.
The ALJ assessed an RFC: exertional limits to lifting 10 pounds, sit 6 hours/stand-walk 2 hours per 8-hour workday; avoid unprotected heights, greater-than-moderate noise, and ladders/ropes/scaffolds (occasional ramps/stairs permitted).
A vocational expert identified representative jobs (election clerk, document preparer, charge-account clerk) consistent with the RFC; ALJ denied benefits (June 1, 2020). Appeals Council denied review; Plaintiff sought judicial review.
Magistrate Judge McAuliffe affirmed the Commissioner, holding the ALJ’s decision supported by substantial evidence and proper legal standards; Plaintiff’s summary-judgment/remand motion was denied.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Step Three — Listings (cardiac)	Taylor says the ALJ failed to parse listing criteria and explain why Listings 4.02/4.05/4.06 (and possibly 4.04) weren't met or equaled.	ALJ provided a multi-page evaluation of cardiac evidence; claimant failed to show she satisfied all specific listing elements (e.g., cyanosis, exercise-test criteria).	No reversible error; plaintiff did not carry burden to show listing criteria met; ALJ’s review adequate.
Step Two — Mental impairments severity	Taylor contends ALJ erred by not finding anxiety/GAD severe, producing incomplete RFC.	State agency reviewers found no severe mental impairment; consultative/medical evidence was pre-onset or showed only mild/unsupported symptoms; ALJ considered mental evidence in RFC.	No reversible error; any step-two omission harmless because ALJ accounted for limitations and record lacked support for severe mental impairment.
VE/DOT conflict re: Reasoning level	Taylor argues RFC should have limited her to simple, routine, repetitive tasks, creating a conflict with DOT Reasoning Level 3 jobs the VE identified.	RFC did not include a limitation to simple, routine, repetitive work; no medical opinion supported such a cognitive restriction; VE testimony properly used.	No error: no apparent conflict because RFC contained no such cognitive limitation and record lacked support for it.
Subjective symptom testimony	Taylor says ALJ improperly discounted her reports of chest pain, fatigue, tachycardia, and cognitive limits without adequate reasons.	ALJ gave specific, clear and convincing reasons: inconsistency with objective medical evidence, lack of corroborating treating opinions, inconsistencies in Plaintiff’s statements (e.g., attendance/records for college), and activities inconsistent with total disability.	ALJ provided clear and convincing reasons; discounting was supported by substantial evidence; any error would be harmless.

Key Cases Cited

Richardson v. Perales, 402 U.S. 389 (objective substantial-evidence standard for administrative findings)
Sullivan v. Zebley, 493 U.S. 521 (claimant must meet all listing criteria to establish equivalence)
Gonzalez v. Sullivan, 914 F.2d 1197 (ALJ need not parse every listing element if decision explains evidentiary basis)
Lewis v. Apfel, 236 F.3d 503 (ALJ must discuss and evaluate evidence supporting conclusions)
Massachi v. Astrue, 486 F.3d 1149 (ALJ must inquire about and resolve apparent conflicts between VE testimony and the DOT)
Gutierrez v. Colvin, 844 F.3d 804 (trigger for ALJ duty to reconcile VE/DOT conflicts is an obvious or apparent conflict)
Zavalin v. Colvin, 778 F.3d 842 (apparent conflict requires reconciliation when VE’s testimony suggests greater demands than claimant can meet)
Garrison v. Colvin, 759 F.3d 995 (two-step analysis for evaluating claimant’s subjective symptom testimony)
Carmickle v. Comm’r of Soc. Sec., 533 F.3d 1155 (harmless-error doctrine when ALJ gives multiple reasons to reject testimony)
Molina v. Astrue, 674 F.3d 1104 (ALJ may consider daily activities and inconsistent statements when assessing credibility)
Bayliss v. Barnhart, 427 F.3d 1211 (RFC should be affirmed if supported by substantial evidence and correct legal standard)