Claim for disability insurance benefits denied

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When an administrative law judge explained his reasons for rejecting a doctor’s opinion and sufficiently discussed plaintiff’s kidney disease, his decision that plaintiff was not disabled was upheld.

Background

Garnett H. filed this action challenging the Social Security Commissioner’s final decision finding him harmless and therefore ineligible for disability insurance benefits and Supplemental Security Income under the Social Security Act. Garnett contends that the administrative law judge, or ALJ, erred by failing to properly consider one of the medical opinions in the record and by failing to discuss his stage III chronic kidney disease. Both parties have filed motions for summary judgment.

Medical opinion

Garnett’s argument fails as the ALJ explains his reasons for rejecting Dr. Conley’s opinion. Neuropsychological test results that showed inattention, restlessness, and slow reaction time also indicated adequate “mental status, intact practical judgment, average intelligence, normal verbal memory, abstract concept formation, and mental flexibility.” The ALJ explained that Dr. Conley’s opinion was inconsistent with the results of these tests.

The ALJ further found that Dr. Conley “expressed an opinion on a matter ․ []

reserved for the Commissioner” and therefore “did not provide[d] formulation as to the evidence that is inherently valuable or persuasive on the issue of whether the claimant is disabled.” The ALJ sufficiently explained that the mixed test results and Dr. Conley’s opinion on an issue reserved for the Commissioner provided reason for the ALJ to reject Dr. Conley’s opinion. I find the ALJ’s assessment of Garnett’s disabilities to be sufficient.

Chronic kidney disease

Garnett next argues that the ALJ erred in formulating Garnett’s physical residual functional capacity by failing to address or discuss his Stage III chronic kidney disease. The court disagrees.

The ALJ’s discussion of Garnett’s kidney disease was sufficient. The ALJ acknowledged that Garnett “was receiving medical treatment for kidney disease, which indicated that his body was retaining fluid and that urine output was slow.” The ALJ repeatedly referred to the accidental swelling of Garnett’s lower extremities. In explaining his decision to restrict Garnett to light work, the administrative law judge said Garnett is “doing well with his kidney impairment.”

Garnett disputes the accuracy of this conclusion, but it originated in a treatment protocol on which the ALJ partially based his decision. Additionally, the ALJ need not consider every conflicting piece of evidence; rather, the ALJ must prepare an opinion that shows how the documents support the decision made.

Attacking whether substantial evidence exists requires more than simply identifying medical records or statements that contradict the ALJ’s findings. The claimant must show that the ALJ used an inappropriate legal standard, failed to consider a relevant part of the record, failed to meet the burden of explanation, or the overwhelming weight of conflicting evidence overcomes the very low standard of substantial evidence. The Fourth Circuit is clear that the ALJ’s findings “as to any fact, if supported by substantial evidence, shall be conclusive.” Here, Garnett did no more than cast doubt on the ALJ’s conclusion.

Contrary to Garnett’s claims, the ALJ provided a detailed summary of Garnett’s physical disabilities, medical records, testimony, and opinion evidence. The ALJ was required to create a narrative discussion that builds a “precise and logical bridge from the evidence to his conclusion,” which the ALJ did in his discussion of the medical and nonmedical evidence, Garnett’s alleged symptoms, and medical opinions from the record.

This narrative discussion allows the court to see how the evidence in the record—both medical and nonmedical—supports the determination of residual functional capacity. Because I was not “left to guess” how the ALJ arrived at his determination of residual functional capacity, I find the ALJ’s conclusion supported by substantial evidence.

Plaintiff’s motion for summary judgment is denied. Defendant’s motion for summary judgment is granted.

Garnett H v Commissioner of Social Security Administration, Case No. 6:22-cv-00039, Sep 28, 2023 WDVA at Lynchburg (Ballow). VLW 023-3-629. 12 p.

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