Angel v. Barnhart

Sara Angel (plaintiff) was denied Social Security disability insurance benefits and supplemental security income based on an administrative-law judge’s (ALJ) finding that Angel was not disabled. The ALJ made the determination at step four of the administration’s five-step sequential process for determining disability after finding the following: at step one, that Angel was not engaging in substantial gainful activity; at step two, that she has severe back and bladder impairments; and at step three, that her impairments did not meet or equal the administration’s listing for vertebrogenic disorder, despite Angel’s treating osteopath’s testimony that she met or equaled the listing because of her spinal injuries combined with her bladder dysfunction and lack of tenacity or reflex. The ALJ then found, at step four, that Angel had the residual functional capacity (RFC) to perform a wide range of light work with the following restrictions: lifting no more than 10 pounds on a frequent basis, with a maximum of 20 pounds; standing or walking for no more than two hours at a time, or for no longer than six hours in an eight-hour day; only occasional stooping; and a need to self-catheterize her bladder for 10 to 15 minutes every two to two-and-one-half hours. Based on vocational expert testimony, the ALJ concluded that Angel was not disabled because she could perform her prior work. The ALJ rejected Angel’s testimony that the pain resulting from her back problems prevented her from lifting anything more than a gallon of milk and from standing, sitting, or walking for more than 20 minutes at a time. Angel’s testimony was corroborated by her treating osteopath. The ALJ’s decision became the final decision of the Commissioner of the Social Security Administration, Jo Anne Barnhart. Angel sought judicial review, and a United States district court affirmed the commissioner’s denial. Angel appealed.