Barbara Jones appeals the district court's judgment affirming the Commissioner of Social Security Administration's (SSA) denial of her deceased husband David R. Morris's application for disability insurance benefits and supplementary security income. Morris, born in 1952 with a tenth-grade education, applied for benefits in November 1997, claiming he was unable to work since February 2, 1997, due to heart-related symptoms including shortness of breath, chest pains, and leg pain. Despite significant medical history, including hospitalization for alcoholic cardiomyopathy and congestive heart failure, Morris continued to work until his layoff in February 1997 and briefly held other jobs afterward.
After the initial denial of his claim and subsequent reconsideration, Morris requested a hearing before an administrative law judge (ALJ), where he represented himself with an advocate. He did not provide any physician reports detailing how his condition affected his functional abilities but claimed his doctors had restricted him to lifting no more than ten pounds. The Commissioner presented a residual functional capacity assessment indicating that Morris could lift twenty pounds occasionally and ten pounds frequently, stand or walk for up to six hours in a workday, and sit for about six hours. The ALJ ultimately denied Morris's application, concluding he was not disabled according to the Social Security Act, employing the five-step sequential analysis outlined in SSA regulations.
The ALJ found that Morris met the disability insured status requirement and had not engaged in substantial gainful activity since his condition's onset. He identified Morris' cardiomyopathy as a severe impairment but concluded it did not meet the severity outlined in regulatory listings, thus denying an immediate finding of disability. The ALJ assessed Morris' residual functional capacity (RFC), determining he could not perform past relevant work but could perform jobs available in significant numbers in the national economy, based on a vocational expert's testimony. The ALJ's decision was appealed by Morris’ wife, Barbara Jones, after Morris' death. Jones argued that the ALJ erred in concluding Morris was not disabled, claiming his condition met or equaled listed impairments, that the ALJ failed to provide for further medical examination, improperly relied on the vocational expert, and misapplied the medical-vocational guidelines. Jones also referenced the Supreme Court decision in Barnhart v. Walton, arguing that a claimant with a terminal condition does not need to demonstrate an inability to engage in substantial gainful activity to be considered disabled. The district court upheld the Commissioner’s decision, and Jones appealed, with the review focused on whether the Commissioner’s decision was supported by substantial evidence. The ALJ's reasoning for not classifying Morris' condition as a listed impairment included the requirement that debilitating symptoms must occur during prescribed treatment and be supported by specific medical tests.
The evidence indicates that Morris' symptoms did not manifest while he was on a prescribed treatment regimen, as his condition showed improvement following treatment in March 1997. Reports from April and August 1997 confirm his lack of significant respiratory or cardiac symptoms. Jones failed to demonstrate that Morris underwent necessary tests to meet cardiac listings, and a consulting physician concluded that Morris' condition did not meet any cardiac listing or equivalent impairment. The need for a Residual Functional Capacity (RFC) evaluation arose only because Morris' condition was not found to meet or equal a listing, as specified in 20 C.F.R. 404.1520(e). The opinion from the state agency physician is considered expert evidence and must be given appropriate weight. Although Jones highlighted Morris' medication and symptoms, she did not provide a medical opinion supporting her claims of equivalency to a listed impairment. The ALJ's determination that Morris did not meet or equal a listed impairment was backed by substantial evidence. Jones' assertion that the ALJ violated SSA Ruling 96-6p by not producing additional medical opinion evidence regarding equivalency is unfounded; the ruling does not mandate new evaluations when a state consultant has already addressed the issue. The requirement for expert opinion evidence can be satisfied through various documents from state agency consultants. The directive for updated medical opinions applies only to certain conditions not alleged by Jones. The ALJ also correctly found that a significant number of jobs were available for Morris, concluding he was not disabled under the Act.
Jones argues that the vocational expert's testimony regarding Morris's qualifications for specific jobs contradicts the Dictionary of Occupational Titles (DOT), claiming those positions require a higher skill level than Morris possesses. However, the DOT classifies the surveillance system monitor role as unskilled (SVP of 2), with around 75,000 such jobs available. Although the other identified jobs have higher SVP ratings, Morris's work history supports his capability for those roles. The ALJ found substantial evidence that a significant number of jobs were available to Morris.
Jones also claims the ALJ improperly relied on rule 201.19 of the medical-vocational guidelines to conclude that Morris was not disabled. The ALJ clarified that this rule would only apply if Morris could perform a full range of sedentary work, which he found he could not, thus necessitating an evaluation of job availability. Consequently, the ALJ's decision did not solely depend on rule 201.19.
Furthermore, Jones references Barnhart v. Walton to argue that Morris should have been deemed disabled due to his eventual death from his ailments. However, this interpretation is flawed, as Walton specifies that the definition of disability requires a prolonged inability to engage in substantial gainful activity, which Morris did not meet at the time of the ALJ's decision. The court affirms the district court's judgment, concluding that the ALJ's determinations were supported by substantial evidence.
