JALBERT v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER

CourtDistrict Court, D. Maine
DecidedJanuary 31, 2025
Docket2:24-cv-00042
StatusUnknown

This text of JALBERT v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER (JALBERT v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
JALBERT v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER, (D. Me. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MAINE

DAVID J., ) ) Plaintiff ) ) v. ) No. 2:24-cv-00042--LEW ) MICHELLE KING, ) Acting Commissioner of ) Social Security, ) ) Defendant )

REPORT AND RECOMMENDED DECISION

The Plaintiff in this Social Security Disability and Supplemental Security Income appeal contends that the Administrative Law Judge (ALJ) erred by relying on the testimony of a medical expert who did not hear the Plaintiff’s testimony about his subjective fibromyalgia symptoms. See Plaintiff’s Brief (ECF No. 12) at 3.1 I discern no harmful error and recommend that the Court affirm the Commissioner’s decision. I. Background

The Plaintiff applied for benefits in 2019. See Record at 16. He appealed the final unfavorable decision on those claims to this Court, and the Commissioner ultimately agreed that his case should be remanded for further proceedings. See David J. v. Soc. Sec. Admin. Comm’r, No. 2:22-cv-00174-JDL. On remand, the Plaintiff’s 2019 applications were consolidated with his subsequent 2022 applications

1 The Plaintiff raised other arguments in his brief but withdrew them at oral argument. and returned to an ALJ for a hearing. See Record at 629. The ALJ held that hearing in May 2023, following which she issued a written decision finding the Plaintiff not disabled. See id. at 629-41. In her decision, the ALJ found that the Plaintiff had the

severe impairments of lumbar degenerative disc disease, irritable bowel syndrome, and fibromyalgia. See id. at 632. Considering those impairments, the ALJ found that the Plaintiff had the residual functional capacity (RFC) to perform light work as defined in 20 C.F.R. §§ 404.1567(b) and 416.967(b) except that he could occasionally use foot controls bilaterally; could occasionally climb ramps and stairs but never ladders, ropes, or scaffolds; could occasionally balance, stoop, kneel, crouch, and

crawl; could never work at unprotected heights or with dangerous moving machinery; and needed to work in an office space with a bathroom facility located within one-hundred yards of his workstation. See id. at 633. The ALJ found that the Plaintiff could perform his past relevant work as a tube bender with such an RFC— or, alternatively, could perform other jobs existing in significant numbers in the national economy—and was therefore not disabled. See id. at 639-41. The Plaintiff elected not to request review of the ALJ’s decision by the Appeals Council, making

that decision the final decision of the Commissioner sixty-one days after October 25, 2023, the date of notice of the unfavorable decision. See id. at 626-28; 20 C.F.R. §§ 404.984(d), 416.1484(d). II. Standard of Review

A final decision of the Commissioner is subject to judicial review to determine whether it is based on the correct legal standards and supported by substantial evidence. See 42 U.S.C. §§ 405(g), 1383(c)(3); Seavey v. Barnhart, 276 F.3d 1, 9 (1st Cir. 2001). Substantial evidence in this context means evidence in the administrative record that a reasonable mind could accept as adequate to support an

ALJ’s findings. See Biestek v. Berryhill, 587 U.S. 97, 102-03 (2019). If an ALJ’s findings are supported by substantial evidence, they are conclusive even if the record could arguably support a different result. See Irlanda Ortiz v. Sec’y of Health & Hum. Servs., 955 F.2d 765, 769 (1st Cir. 1991). But an ALJ’s findings “are not conclusive when derived by ignoring evidence, misapplying the law, or judging matters entrusted to experts.” Nguyen v. Chater, 172 F.3d 31, 35 (1st Cir. 1999).

III. Discussion

The Plaintiff argues that the ALJ committed reversible error in discounting his subjective complaints of fibromyalgia-related pain and fatigue based entirely on the objective medical evidence of record and compounded this error by relying on the testimony of agency nonexamining consultant Arnold Ostrow, M.D., who also relied solely on the objective medical evidence and did not hear the Plaintiff’s testimony in violation of agency policy. See Plaintiff’s Brief at 6-14. He urges this Court to follow the Fourth Circuit in holding “that ALJs may not rely on objective medical evidence (or the lack thereof)—even as just one of multiple factors—to discount a claimant’s subjective complaints regarding symptoms of fibromyalgia” because the impairment “does not produce such evidence.” Arakas v. Comm’r, Soc. Sec. Admin., 983 F.3d 83, 97 (4th Cir. 2020); see Plaintiff’s Brief at 13-14. As the Plaintiff’s arguments highlight, fibromyalgia is a “syndrome of chronic pain” with an “uncertain cause” and sufferers often show no signs of musculoskeletal or neurological abnormalities upon examination. Johnson v. Astrue, 597 F.3d 409,

410 (1st Cir. 2009) (cleaned up). Recognizing the challenges of assessing such an impairment in the disability benefits context, the Commissioner published SSR 12-2p, 2012 WL 3104869 (July 25, 2012), which provides criteria for determining whether fibromyalgia constitutes a medically determinable impairment (MDI) and guidance on how to consider it during the sequential evaluation process. If fibromyalgia is found to be an MDI, the ALJ must, as with other impairments,

“evaluate the intensity and persistence of the [claimant]’s pain” and other symptoms to “determine the extent to which” they limit the claimant’s “capacity for work.” Id. at *5. And if the “objective medical evidence does not substantiate the” claimant’s “statements about the intensity, persistence, and functionally limiting effects” of his fibromyalgia symptoms, the ALJ must consider other evidence such as the claimant’s daily activities, medication and treatment history, and statements by others about the claimant’s symptoms. Id.

But just because fibromyalgia “symptoms are often not supportable by objective medical evidence,” does not mean claimants with fibromyalgia are “automatically entitle[d] . . . to disability benefits.” Vance v. Comm’r of Soc. Sec., 260 F. App’x 801, 806 (6th Cir. 2008). Indeed, ALJs are not obligated to “accept a claimant’s allegations regarding the extent of his” fibromyalgia-related “limitations at face value,” Downs v. Comm’r, Soc. Sec. Admin., No. 2:13-CV-02-DBH, 2014 WL 220697, at *4 (D. Me. Jan. 21, 2014), and the claimant must still “adduce ‘sufficient objective evidence to support a finding that [his] impairment(s) so limit[] [his] functional abilities that it precludes him . . . from performing any substantial

gainful activity.’” Jennifer T. v. Kijakazi, No. 2:22-cv-00047-JAW, 2023 WL 118876, at *2 (D. Me. Jan. 6, 2023) (rec. dec.) (quoting SSR 12-2p, 2012 WL 3104869, at *2), aff’d, 2023 WL 1100310 (D. Me. Jan. 30, 2023); cf. Ovist v. Unum Life Ins. Co. of Am., 14 F.4th 106, 123 (1st Cir. 2021) (noting that, unlike symptoms, the functionally limiting effects of fibromyalgia “do lend themselves to objective analysis” (cleaned up)).

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Related

Seavey v. Social Security
276 F.3d 1 (First Circuit, 2001)
Johnson v. Astrue
597 F.3d 409 (First Circuit, 2010)
Vance v. Commissioner of Social Security
260 F. App'x 801 (Sixth Circuit, 2008)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Esin Arakas v. Commissioner, Social Security
983 F.3d 83 (Fourth Circuit, 2020)
Ovist v. Unum Life Ins Co(.) of America
14 F.4th 106 (First Circuit, 2021)

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Bluebook (online)
JALBERT v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jalbert-v-social-security-administration-commissioner-med-2025.