Shari L. v. Bisignano: No Error in Rejecting Treating Source Limitations

Shari L. filed applications for Disability Insurance Benefits and Supplemental Security Income alleging disability beginning August 1, 2021. She previously worked as an underwriter and asserted that she was unable to continue working due to chronic pain, multilevel degenerative disc disease, scoliosis, bulging discs, and sciatica. She later reported that ongoing pain negatively affected her mental state.

The Social Security Administration denied the applications at the initial level in September 2022 and again on reconsideration in April 2023. State agency reviewers determined that Shari L. had severe physical impairments but that any mental impairments were non-severe. They concluded she could perform a range of light work with postural and hazard-related limitations.

Administrative Hearing and ALJ Findings

An Administrative Law Judge conducted a hearing in December 2023, during which Shari L. testified and a vocational expert provided testimony. In February 2024, the ALJ issued a written decision concluding that Shari L. was not disabled under the Social Security Act.

The ALJ found that Shari L. had not engaged in substantial gainful activity since the alleged onset date. The ALJ determined that she had severe physical impairments affecting her lumbar spine but that her mental impairments caused no more than minimal limitations.

The ALJ assessed a residual functional capacity for a range of light work. The RFC included limitations such as only occasional postural activities, no climbing of ladders, ropes, or scaffolds, and no concentrated exposure to workplace hazards. In evaluating the medical evidence, the ALJ found persuasive the opinions of state agency physicians and consultative examiners, who concluded that Shari L. could perform light work and had no mental work-related limitations.

Based on this RFC, the ALJ found that Shari L. could perform her past relevant work as an underwriter as it is generally and actually performed. The ALJ therefore concluded that she was not disabled.

Appeals Council Review

Shari L. sought review by the Appeals Council. In September 2024, the Appeals Council denied the request for review, making the ALJ’s decision the final decision of the Commissioner of Social Security.

Federal Court Review

Shari L. filed an action in the United States District Court for the Central District of California seeking judicial review of the denial of benefits. The parties consented to proceed before a magistrate judge.

Before the court, Shari L. raised two primary issues. She asserted that the ALJ failed to properly evaluate medical opinions from Dr. Alan Rosenthal and Dr. Zahra Sherazi, which described limitations that would preclude work. She also asserted that the ALJ failed to adequately explain why the RFC included no mental limitations.

Evaluation of Medical Opinion Evidence

The court reviewed the ALJ’s decision under the regulations governing claims filed after March 27, 2017. Under those regulations, an ALJ evaluates the persuasiveness of medical opinions primarily based on supportability and consistency.

The court determined that the ALJ adequately explained why the opinions of Dr. Rosenthal and Dr. Sherazi were not adopted. The ALJ discussed that those opinions relied heavily on subjective complaints and were not supported by objective clinical findings. The ALJ also found the opinions inconsistent with examination findings and Shari L.’s reported daily activities.

Although the ALJ did not expressly label those opinions as persuasive or unpersuasive, the court found that the ALJ’s reasoning made clear how the opinions were evaluated. Any failure to use specific terminology was found to be harmless because substantial evidence supported the RFC assessment.

Mental Limitations Analysis

The court also addressed the claim that the ALJ failed to explain the absence of mental limitations in the RFC. The court noted that no medical source opined that Shari L. had work-related mental limitations. A consultative psychological examiner and state agency reviewers concluded that her mental impairments were non-severe and caused no more than mild limitations.

The court found that the ALJ adequately discussed this evidence and properly incorporated it into the RFC determination. Because the ALJ found no mental limitations supported by the record, the ALJ was not required to include such limitations in the RFC or in the vocational analysis.

The Court’s Decision

The district court concluded that the ALJ’s decision was supported by substantial evidence and free from material legal error. The court affirmed the Commissioner’s denial of benefits.

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