7th Circuit: No ‘qualitative’ limitations in disability denial

An Indiana woman who was denied Social Security disability benefits failed to convince the 7^th Circuit Court of Appeals that an administrative law judge erred by not considering the mental difficulty she experienced when being around more than five people at once.

Trisha Reynold applied for disability benefits, claiming she suffers from a variety of ailments that prevent her from working. Among her difficulties she listed migraines, vertigo, an inability to stand for more than 10 minutes and the anxiety that comes when she is around more than five people.

The ALJ determined Reynolds had the residual functional capacity to perform a full range of work with certain limitations. In particular, the record showed that while Reynolds occasionally exhibited anger, on the whole she was cooperative, alert and exhibited an appropriate mood.

Moreover, the ALJ observed that the RFC found Reynolds was “capable of occasional interaction with co-workers and supervisors and no interaction with the general public.”

In reaching its conclusion, the ALJ rejected three state agency consultants’ opinions that were unfavorable to Reynolds and instead relied on the one that found she could respond appropriately to “brief supervision and interactions [with] co-workers.”

The U.S. District Court for the Northern District of Indiana affirmed. It held the ALJ did not have to impose “qualitative” limitations on Reynolds’ interactions with supervisors and co-workers because the opinion the ALJ relied upon maintained she could interact with other employees.

Reynolds countered by pointing to another psychological evaluation that concluded she “will likely struggle to get along with her supervisors and coworkers due to her mental health issues.” However, the ALJ rejected that evaluation, explaining the opinion on qualitative limitation was speculative and unpersuasive.

The 7^th Circuit affirmed in Trisha K. Reynolds v. Kilolo Kijakazi, Acting Commissioner of Social Security, 21-1624.

“Put another way, evidence that Reynolds sometimes struggles to interact appropriately with others does not mean an occasional interaction limitation was insufficient in this case,” Judge Amy St. Eve wrote for the appellate court. “Indeed, the ALJ’s determination that Reynolds could handle ‘occasional’ interactions with supervisors and coworkers ‘but no interaction with the general public’ is consistent with Reynolds’s testimony that she gets anxious when she is around ‘more than five people.’”