Kohler v. Astrue

Kathy Kohler (plaintiff) applied for disability benefits due to a bipolar disorder, which she was diagnosed with 10 years prior. Kohler submitted medical evidence of treatment dating back to her diagnosis, including a prescription of lithium to manage her manic and depressive episodes. Kohler’s medical records generally indicated that Kohler had good results controlling her disorder with medication, although she was hospitalized at least twice, for two weeks each time, and had some complications with her medication dosage. Medical records further indicated that Kohler’s impairment caused moderate limitations in her social functioning and in her abilities to maintain focus for extended periods, to complete normal workday tasks and perform at a consistent pace without an inordinate number of breaks, and to interact appropriately with the general public. An administrative-law judge (ALJ) found that Kohler’s mental impairment was severe but concluded, with little analysis, that the impairment did not meet or equal the level of severity required of the administration’s listing for bipolar disorder. The ALJ then evaluated Kohler’s residual functional capacity (RFC) and found that Kohler displayed only mild, well-controlled symptoms and had no more than occasional problems in social and occupational functioning. The ALJ concluded that Kohler had the RFC to return to her prior work thus was not disabled. The ALJ’s decision became the final decision of the Commissioner of the Social Security Administration, Michael Astrue (defendant), and Kohler sought judicial review. A district court upheld the commissioner’s denial. Kohler appealed.