Unreported / Non-Citable
Background
Celina Cassandra Ramos sought judicial review of the Commissioner’s denial of disability insurance benefits and supplemental security income. She filed both applications on February 8, 2023, alleging disability beginning January 17, 2023. After initial and reconsideration denials, an ALJ held a telephone hearing on September 9, 2025, and issued an unfavorable decision on September 26. The Appeals Council denied review on December 12, 2025, and Ramos filed this action on February 4, 2026.
The ALJ found severe impairments including bipolar disorder, borderline personality disorder, PTSD, anxiety, depression, and substance disorder, but no listed impairment. The resulting RFC allowed all exertional levels with environmental and mental restrictions: no climbing ladders, ropes, or scaffolds; no unprotected heights, dangerous moving machinery, or other hazards; simple and detailed but not complex instructions for up to two-hour periods; a nonpublic work environment with only occasional coworker and supervisor interaction; no fast-paced production or assembly-line work requiring more than frequent hand use; adaptation to occasional workplace changes with advance notice; and no work around large groups of people. With no past relevant work, the ALJ relied on vocational testimony identifying housekeeping cleaner, marker, and routing clerk jobs and concluded Ramos was not disabled.
The Court’s Holding
Ramos first argued that the ALJ lacked clear and convincing reasons to reject her psychological symptom allegations. The magistrate judge rejected that challenge, identifying largely normal mental-status examinations, improvement with treatment, and daily activities as supporting reasons. Although television viewing, bird watching, walking around the block, and paying attention at home added little, other activities—including meal preparation, laundry, driving, shopping, household chores, and caregiving—supported the ALJ’s assessment. The magistrate judge also noted that the RFC incorporated limitations for simple tasks and minimal coworker contact, while Ramos did not identify additional limitations that should have been included.
Ramos’s second argument principally challenged the ALJ’s treatment of consultative psychologist Dia Gunnarsson’s opinion. Gunnarsson assessed moderate-to-marked social-interaction and adaptation limitations based partly on Ramos’s subjective complaints. The magistrate judge found the ALJ’s partial rejection adequately explained under supportability and consistency: most examination findings were normal or benign, and behavioral-health records describing Ramos’s care for children conflicted with the asserted adaptation and stress-management limitations. The RFC’s nonpublic setting and occasional contact restrictions addressed social functioning, and the record did not support more restrictive limitations.
The recommendation therefore was to deny Ramos’s motion, grant the Commissioner’s cross-motion, affirm the Commissioner’s decision, and direct judgment for the Commissioner. These were findings and recommendations, not a final district-court judgment. The document provides for submission to the assigned district judge and written objections within fourteen days after service, warning that failure to object may waive appellate rights.
Key Takeaways
- The magistrate judge treated normal mental-status findings, treatment improvement, and functionally significant daily activities together as clear and convincing support for partially rejecting Ramos’s symptom testimony.
- The court expressly discounted the persuasive value of passive activities such as television viewing and bird watching rather than treating every reported activity as evidence of work capacity.
- Under the post-2017 medical-opinion rules, the ALJ adequately addressed supportability by comparing Gunnarsson’s assessed limitations with her own predominantly normal examination findings.
- The ALJ’s comparison of the opinion with another provider’s behavioral-health notes supplied a consistency analysis even though the ALJ used the word “supported.”
- The recommended affirmance remains subject to district-judge review and the document’s fourteen-day objection process.
Why It Matters
The recommendation illustrates how an ALJ can satisfy the clear-and-convincing standard without linking every item of testimony to every contrary record citation. It distinguishes weak activity evidence from caregiving, household, and independent-living activities that more directly bear on alleged psychiatric limitations. It also shows that incorporating some symptoms into the RFC can matter when a claimant does not specify what additional restrictions the evidence requires.
On medical opinions, the analysis separates supportability—whether the examiner’s own findings support the opinion—from consistency with other record evidence. The court’s footnote explains that substance controls even when the ALJ’s terminology is imprecise. The recommendation does not establish a final judgment or resolve any later objections; it leaves the prescribed district-court review process to follow.