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Mikel v. Commissioner of Social Security, Not Reported in Fed. Supp., 2015 WL 7177240, 222 Soc.Sec.Rep.Serv. 743

Facts

Jeanette L. Mikel applied for DIB and SSI in July 2011, claiming disability due to various medical conditions, including COPD, bipolar disorder, and degenerative disc disease, with an alleged onset date of January 1, 2009. After a hearing, the ALJ denied her application, concluding that she had severe impairments but could perform light work with certain limitations. Mikel contested the ALJ's findings, arguing that the jobs identified by the vocational expert exceeded her RFC and that the ALJ improperly rejected medical opinions supporting her claim.

Plaintiff was born in 1964, and was almost 45 years old when she allegedly became disabled. (Tr. 160). She was 5'3" tall and weighed 256 pounds. She said she was unable to work because of COPD, bipolar disorder, bulging disc and bone spurs in her spine, depression and anxiety/panic disorder. (Tr. 164).

Issue

Did the ALJ err in determining Mikel's residual functional capacity and in relying on the vocational expert's testimony regarding available jobs?

Plaintiff raises the following issues: 1. The ALJ did not meet his burden at step 5 because the jobs testified to by the Vocational Expert (VE) exceeded plaintiff' residual functional capacity (RFC). 2. The RFC findings were not supported by substantial evidence because the ALJ rejected all of the medical opinions in evidence and relied on his own medical conclusions. 3. The credibility analysis was erroneous.

Rule

The court reviews the Commissioner's decision to ensure it is supported by substantial evidence and that no legal errors occurred. The ALJ must provide a thorough analysis of the medical evidence and cannot ignore conflicting evidence.

To qualify for DIB or SSI, a claimant must be disabled within the meaning of the applicable statutes. For these purposes, 'disabled' means the 'inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.' 42 U.S.C. §§ 423(d)(1)(A) and 1382c(a)(3)(A).

Analysis

The court found that the ALJ's determination of Mikel's RFC was not supported by substantial evidence, particularly because the ALJ rejected the treating physician's opinion without adequate justification. Additionally, the court noted discrepancies between the hypothetical posed to the vocational expert and the RFC findings, which led to the identification of jobs that Mikel could not perform based on her limitations.

The Court has reviewed and considered the entire evidentiary record in formulating this Memorandum and Order. The following summary of the record is directed to the points raised by plaintiff.

Conclusion

The court reversed the Commissioner's decision and remanded the case for further consideration, emphasizing that the ALJ's errors necessitated a reevaluation of the evidence.

The Commissioner’s final decision denying Jeanette L. Mikel’s application for social security disability benefits is REVERSED and REMANDED to the Commissioner for rehearing and reconsideration of the evidence, pursuant to sentence four of 42 U.S.C. § 405(g).

Who won?

Jeanette L. Mikel prevailed in the case because the court found that the ALJ's decision was not supported by substantial evidence and that the vocational expert's testimony was flawed.

The Court wishes to stress that this Memorandum and Order should not be construed as an indication that the Court believes that Ms. Mikel was disabled during the relevant time period or that she should be awarded benefits.

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