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Lean v. Saul

United States District Court, D. New Mexico

July 31, 2019

ERNESTO M. LEAN, Plaintiff,
ANDREW SAUL, Commissioner of Social Security, [1] Defendant.



         THIS MATTER is before the Court on the Social Security Administrative Record filed September 4, 2018, Doc. 12, in support of Plaintiff Ernesto M. Lean's Complaint, Doc. 1, seeking review of the decision of Defendant Andrew Saul, Commissioner of the Social Security Administration, denying Plaintiff's claim for disability insurance benefits under Title II and Title XVI of the Social Security Act, 42 U.S.C. § 401 et seq. On January 25, 2019, Plaintiff filed her Motion To Remand For Payment Of Benefits, Or In The Alternative, For Rehearing, With Supporting Memorandum. Doc. 21. The Commissioner filed a Brief in Response on March 18, 2019, Doc. 22, and Plaintiff filed a Reply on April 12, 2019, Doc. 23. The Court has jurisdiction to review the Commissioner's final decision under 42 U.S.C. §§ 405(g) and 1383(c). Having meticulously reviewed the entire record and the applicable law and being fully advised in the premises, the Court finds the Motion is not well taken and is DENIED.

         Background and Procedural Record

         Claimant Ernesto M. Lean[3] suffers from the following severe impairments: pituitary macroadenoma; headaches; lumbar spine and cervical spine degenerative disc disease; bilateral bunions and hallux valgus; diabetes; psychosis, not otherwise specified; major depression, recurrent; PTSD; and methamphetamine abuse, in remission. Administrative Record (“AR”) at 14. She alleges that she became disabled as of November 25, 2013. AR 11. She has a high school degree and completed two years of college for an associate's degree. AR 321, 1078. She has past work as a caregiver and a fry cook. AR 117-19.

         On May 6, 2014, Ms. Lean filed a claim of disability under Titles II and XVI. AR 152. Her applications were initially denied on September 4, 2014, AR 152-53, and upon reconsideration on March 23, 2015, AR 170-71. Administrative Law Judge (“ALJ”) James Bentley conducted a hearing on December 22, 2016. AR 108. Ms. Lean appeared in person at the hearing with attorney representative Don Smith. AR 108. The ALJ took testimony from Ms. Lean and an impartial vocational expert (“VE”), Amy Donaldson. AR 108.

         On May 17, 2017, ALJ Bentley issued an unfavorable decision. AR 8. The Appeals Council denied review on April 21, 2018, noting that Ms. Lean submitted additional evidence but declining to consider it. AR 1-2. The ALJ's decision is the Commissioner's final decision for purposes of judicial review. Ms. Lean proceeded to federal court on May 31, 2018. Doc. 1. Because the parties are familiar with Ms. Lean's medical history, the Court reserves discussion of the medical records relevant to this appeal for its analysis.

         Applicable Law

         A. Disability Determination Process

         An individual is considered disabled if she is unable “to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A) (pertaining to disability insurance benefits); see also Id. § 1382(a)(3)(A) (pertaining to supplemental security income disability benefits for adult individuals). The Social Security Commissioner has adopted the familiar five-step sequential evaluation process (“SEP”) to determine whether a person satisfies the statutory criteria as follows:

(1) At step one, the ALJ must determine whether the claimant is engaged in “substantial gainful activity.”[4] If the claimant is engaged in substantial gainful activity, she is not disabled regardless of her medical condition.
(2) At step two, the ALJ must determine the severity of the claimed physical or mental impairment(s). If the claimant does not have an impairment(s) or combination of impairments that is severe and meets the duration requirement, she is not disabled.
(3) At step three, the ALJ must determine whether a claimant's impairment(s) meets or equals in severity one of the listings described in Appendix 1 of the regulations and meets the duration requirement. If so, a claimant is presumed disabled.
(4) If, however, the claimant's impairments do not meet or equal in severity one of the listings described in Appendix 1 of the regulations, the ALJ must determine at step four whether the claimant can perform her “past relevant work.” Answering this question involves three phases. Winfrey v. Chater, 92 F.3d 1017, 1023 (10th Cir. 1996). First, the ALJ considers all of the relevant medical and other evidence and determines what is “the most [claimant] can still do despite [her physical and mental] limitations.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). This is called the claimant's residual functional capacity (“RFC”). Id. §§ 404.1545(a)(3), 416.945(a)(3). Second, the ALJ determines the physical and mental demands of claimant's past work. Third, the ALJ determines whether, given claimant's RFC, the claimant is capable of meeting those demands. A claimant who is capable of returning to past relevant work is not disabled.
(5) If the claimant does not have the RFC to perform her past relevant work, the Commissioner, at step five, must show that the claimant is able to perform other work in the national economy, considering the claimant's RFC, age, education, and work experience. If the Commissioner is unable to make that showing, the claimant is deemed disabled. If, however, the Commissioner is able to make the required showing, the claimant is deemed not disabled.

See 20 C.F.R. § 404.1520(a)(4) (disability insurance benefits); 20 C.F.R. § 416.920(a)(4) (supplemental security income disability benefits); Fischer-Ross v. Barnhart, 431 F.3d 729, 731 (10th Cir. 2005); Grogan v. Barnhart, 399 F.3d 1257, 1261 (10th Cir. 2005).

         The claimant has the initial burden of establishing a disability in the first four steps of this analysis. Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987). The burden shifts to the Commissioner at step five to show that the claimant is capable of performing work in the national economy. Id. A finding that the claimant is disabled or not disabled at any point in the five-step review is conclusive and terminates the analysis. Casias v. Sec'y of Health & Human Serv., 933 F.2d 799, 801 (10th Cir. 1991).

         B. Standard of Review

         This Court must affirm the Commissioner's denial of social security benefits unless (1) the decision is not supported by “substantial evidence” or (2) the ALJ did not apply the proper legal standards in reaching the decision. 42 U.S.C. § 405(g); Hamlin v. Barnhart, 365 F.3d 1208, 1214 (10th Cir. 2004); Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004); Casias, 933 F.2d at 800-01. In making these determinations, the Court “neither reweigh[s] the evidence nor substitute[s] [its] judgment for that of the agency.'” Bowman v. Astrue, 511 F.3d 1270, 1272 (10th Cir. 2008). “[W]hatever the meaning of ‘substantial' in other contexts, the threshold for such evidentiary sufficiency is not high.” Biestek v. Berryhill, 139 S.Ct. 1148, 1154 (2019). Substantial evidence “is ‘more than a mere scintilla.'” Id. (quoting Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). “It means-and means only-such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id. (internal quotation marks omitted).

         A decision “is not based on substantial evidence if it is overwhelmed by other evidence in the record, ” Langley, 373 F.3d at 1118, or “constitutes mere conclusion, ” Musgrave v. Sullivan, 966 F.2d 1371, 1374 (10th Cir. 1992). The agency decision must “provide this court with a sufficient basis to determine that appropriate legal principles have been followed.” Jensen v. Barnhart, 436 F.3d 1163, 1165 (10th Cir. 2005). Therefore, although an ALJ is not required to discuss every piece of evidence, “the record must demonstrate that the ALJ considered all of the evidence, ” and “the [ALJ's] reasons for finding a claimant not disabled” must be “articulated with sufficient particularity.” Clifton v. Chater, 79 F.3d 1007, 1009-10 (10th Cir. 1996). But where the reviewing court “can follow the adjudicator's reasoning” in conducting its review, “and can determine that correct legal standards have been applied, merely technical omissions in the ALJ's reasoning do not dictate reversal.” Keyes-Zachary v. Astrue, 695 F.3d 1156, 1166 (10th Cir. 2012). The court “should, indeed must, exercise common sense.” Id. “The more comprehensive the ALJ's explanation, the easier [the] task; but [the court] cannot insist on technical perfection.” Id.


         In support of her Motion to Remand, Ms. Lean raises three main arguments. First, she argues that the ALJ erred at step four by improperly: assessing the effects of Ms. Lean's headaches; disregarding treating psychiatrist Dr. Nathaniel Sharon's opinion assigning a Global Assessment of Functioning (“GAF”) score; rejecting the opinion of LASAC Don Smith, Ms. Lean's treating counselor; assessing Ms. Lean's social limitations; rejecting the opinion of Dr. Camellia Clark, consultative examiner; rejecting the opinion of PA Lucas Lujan, her treating physician assistant; and assessing Ms. Lean's subjective symptom evidence. Doc. 21 at 9-21. Second, she argues that the ALJ erred at step five by failing to resolve a conflict between the VE testimony and the Dictionary of Occupational Titles (“DOT”). Doc. 21 at 21-22. Finally, she argues that the Appeals Council should have considered her new evidence. Doc. 21 at 23-27. Ms. Lean argues for this Court to reverse and remand with instructions for the Commissioner to issue disability benefits; in the alternative, she requests a remand for rehearing. Doc. 21 at 27.

         I. The ALJ Did Not Err At Step Four.

         In assessing a claimant's RFC at step four, the ALJ must consider the combined effect of all of the claimant's medically determinable impairments, and review all of the evidence in the record. Wells v. Colvin, 727 F.3d 1061, 1065 (10th Cir. 2013). “[M]ost importantly, the ALJ's RFC assessment must include a narrative discussion describing how the evidence supports each conclusion, citing specific medical facts and nonmedical evidence.” Id. (internal quotation marks and alterations omitted). “Requiring the ALJ to make specific findings on the record at each phase of the step four analysis provides for meaningful judicial review.” Winfrey v. Chater, 92 F.3d 1017, 1025 (10th Cir. 1996).

         Here, the ALJ found that, taking into account her severe impairments, Ms. Lean is capable of performing less than the full range of light work. AR 18. She requires a sit/stand option and is limited to simple or detailed, but not complex, tasks. AR 4501. In her Motion, Ms. Lean argues that this finding was error and that the ALJ should have found her disabled. Although Ms. Lean identifies seven step-four errors which she discusses seriatim, the Court will divide them into two categories: (1) the ALJ's consideration of medical evidence and (2) the ALJ's consideration of medical opinions.

         A. The ALJ properly evaluated the medical evidence.

         Ms. Lean argues that the ALJ improperly discounted medical evidence related to her headaches, Doc. 21 at 9-11; her limitations on social functioning, Doc. 21 at 15-17; and her subjective symptom evidence, Doc. 21 at 20-21. The Court finds that the ALJ's discussion of the medical evidence was sufficient.

         “The regulations require the ALJ to consider all evidence in the case record when he makes a determination or decision whether claimant is disabled.” Keyes-Zachary v. Astrue, 695 F.3d 1156, 1166 (10th Cir. 2012) (citing 20 C.F.R. § 404.1520(a)(3)) (internal quotation marks and alterations omitted). An ALJ may not “pick and choose among medical reports, using portions of evidence favorable to his position while ignoring other evidence.” Hardman v. Barnhart, 362 F.3d 676, 681 (10th Cir. 2004). However, while “[t]he record must demonstrate that the ALJ considered all of the evidence, ” he “is not required to discuss every piece of evidence.” Clifton v. Chater, 79 F.3d 1007, 1009-10 (10th Cir. 1996) (emphasis added). “Rather, in addition to discussing the evidence supporting his decision, the ALJ also must discuss the uncontroverted evidence he chooses not to rely upon, as well as significantly probative evidence he rejects.” Id.

         To meet her burden in this Court, Ms. Lean must not only “point[] to evidence that she claims the ALJ failed to discuss, ” but also “say why it was significantly probative.” Mays v. Colvin, 739 F.3d 569, 576 (10th Cir. 2014). The Court will not do so for her. Id.

         1. Headaches

         At step two, the ALJ found that Ms. Lean's impairment of headaches is severe. AR 14. At step three, he found that there is no listing for headaches and Ms. Lean's headaches do not equal the listing for epilepsy or any other listing. AR 15. He discussed evidence that Ms. Lean reported in 2016 that her headaches are generally unresponsive to medications and in 2015 that her symptoms resolved after she took ibuprofen or went to sleep. Id. At step four, the ALJ discussed her history with headaches based on medical evidence from 2014 to 2017. AR 19-20. He remarked that “during a February 11, 2017 emergency room visit, she reported that after she was diagnosed with a brain tumor, she had noticed worse headaches, worse blurry vision, and some right lower extremity weakness” and “[s]he rarely, if ever, complained of headaches after this until diagnosed with pituitary tumor.” AR 20.

She underwent multiple CT head/brain scans, which were normal. The scans showed no evidence of intracranial mass or hemorrhage to suggest an etiology to her chronic headaches. She had no focal neurological deficits, no evidence to suggest meningitis, and no evidence of temporal arteritis or sinusitis or acute infection. Moreover, her history did not suggest a subarachnoid hemorrhage.

         AR 20 (citations omitted). The ALJ concluded:

Based on the above-discussed medical evidence, I find that she is limited to performing, at most, a range of “light” work, noting this is consistent with her report of being able to lift 25 pounds prior to January 30, 2017 motor vehicle accident (with no abnormal finding other than tenderness after the accident) and her report that she can walk one to two miles slowly. She also reported she can sit, but not for a long time. I find that her physical impairments warrant not only occasional postural limitations, but also a sit/stand option, with the parameters enumerated above, to allow her to change positions in order to relive discomfort, but without leaving the workstation so as not to diminish pace or production. Though she only intermittently endorsed orthostatic dizziness and exhibiting no difficulties balancing on examination, I find it reasonable that due to complaint of dizziness she must avoid unprotected heights and dangerous moving machinery. I note, finally, that the newly received medical evidence indicates no additional limitations [from] her pituitary macroadenoma surgery other than post-operative limits that are not expected to last 12 months.

AR 26-27.

         Ms. Lean challenges the entirety of this finding. She argues that “ALJ Bentley ignored the longitudinal and consistent evidence of Ms. Lean's headaches, and failed to include resulting limitations on her ability to function.” Doc. 21 at 9. Ms. Lean contends that the ALJ ignored relevant medical evidence showing that her headaches were severe prior to her diagnosis of a brain tumor. Id. at 10. She argues that the ALJ reached his conclusion by “picking and choosing random evidence.” Doc. 21 at 10. She argues that the result of this error was to improperly disregard “the occupational effects of Ms. Lean's headaches” such as “memory problems, blurry vision, and confusion.” Id. at 11.

         Ms. Lean identifies three specific pieces of evidence she contends the ALJ should have considered:

• Ms. Lean complained of headaches at least 11 times prior to February 24, 2016 (citing AR 499-500, 478-81, 492-93, 635-39, 576-78, 674, 624-26, 1078-79, 908-13, 932-35);
• A January 2017 visit at which Ms. Lean told PA Lucas Lujan that she had recently been to the ER with a headache and blurred vision and that she had headaches “all the time now” (citing AR 1569);
• Dr. Nathaniel Sharon's medical opinion on August 25, 2016 that Ms. Lean had “memory, cognitive and psychotic disturbances from pituitary enlargement” (citing AR 1254);

Doc. 21 at 10.

         The Court finds that this is not significantly probative evidence that the ALJ ignored. To the contrary, the ALJ specifically acknowledged these first two pieces of evidence and cited much of the same record evidence that Ms. Lean cites:

• “On January 9, 2015, she had presented to the emergency room for complaint of headache” . . . . “Prior to this, the claimant had presented to the emergency room on multiple occasions in March through May 2014 for headache complaints” . . . . “[T]he attending physician on the last visit, dated May 30, 2014, noted that she had made ‘multiple vague neurologic complaints including headache and blurry vision even predating the [April 23, 2014] car accident.'” AR 20 (citing AR 850-51, 1178-83, 576-79, 623-27, 634-40 & 625).
• “On January 27, 2017, she told her treating physician assistant Lucas Lujan that she had headaches all the time now” and she discussed with him “a January 20, 2017 emergency room visit” where she disagreed that “the worst headache of her life” was just “experiencing a migraine.” AR 20 (citing 1537-40, 1544-52, 1558-65 & 1569).

         Because the ALJ did consider this evidence, Ms. Lean's argument is really one of failure to properly weigh the evidence. The Court does not reweigh evidence in the ALJ's place; it determines whether the ALJ's opinion is supported by substantial evidence. Here, the ALJ's decision is supported by substantial evidence. The ALJ acknowledged Ms. Lean's complaints of headaches to her providers. However, he chose to give those complaints less weight than Ms. Lean's multiple normal CT scans and the fact that no medical evidence in the record suggested an etiology to her complaints of chronic headaches. AR 20. “The possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency's findings from being supported by substantial evidence. [The court] may not displace the agency's choice between two fairly conflicting views, even though the court would justifiably have made a different choice had the matter been before it de novo.” Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007). The ALJ's discussion is sufficient on these points.

         As for the third piece of evidence Ms. Lean points to, the Court agrees that the ALJ did not specifically discuss treating psychiatrist Dr. Sharon's August 25, 2016 statement that Ms. Lean had “memory, cognitive and psychotic disturbances from pituitary enlargement.” Cf. Doc. 1 at 10 (citing AR 1249-54). Instead, the ALJ mentioned this visit only to note that Dr. Sharon took over Ms. Lean's medication management, continuing some medications and altering another. AR 25. The Court does not agree, however, that anything in these treatment notes constitutes specifically probative evidence the ALJ was required to discuss.

         The statement in question provides in full: “I am concerned there are some memory, cognitive and psychotic disturbances from pituitary enlargement and will also need to work closely with endocrine.” AR 1254. There are no non-speculative statements in this treatment note assigning limitations which the ALJ was required to discuss. Paulsen v. Colvin, 665 Fed.Appx. 660, 666 (10th Cir. 2016) (the ALJ did not have to assign a specific weight to a doctor's statement that the claimant “probably has difficulty with concentration and remembering because of attention problems” because the doctor did not assign any functional limitations); see Keyes-Zachary v. Astrue, 695 F.3d 1156, 1164 (10th Cir. 2012) (the ALJ was not required to assign a weight to “observations” that do not “offer[] an assessment of the effect of [the claimant]'s mental limitations on her ability to work, ” especially where “[t]he file includes much more directly relevant evidence on these issues”); Cowan v. Astrue, 552 F.3d 1182, 1189 (10th Cir. 2008) (statement regarding what a doctor does not know is not “a true medical opinion”); Blazevic v. Colvin, No. 14-2394, 2015 WL 5006139, at *10 (D. Kan. Aug. 20, 2015) (physician's statement that “I am very concerned about [claimant]'s ability to maintain steady employment at the present time due to his symptomatology” was “not an opinion” as it expresses “uncertainty regarding [claimant]'s ability, rather than his opinion that [claimant] can or cannot maintain steady employment”). Dr. Sharon is a psychiatrist, not a neurologist, and nowhere in the pages cited by Ms. Lean does he offer an opinion about her functional limitations due to headaches specifically. AR 1249-54.

         Ms. Lean also argues that the combined evidence of her headaches is significantly probative because “when considered in its entirety, the medical records reveal the occupational effects of Ms. Lean's headaches, ” such as “memory problems, blurry vision, and confusion.” Doc. 21 at 11. Again, however, the ALJ thoroughly discussed Ms. Lean's blurry vision (at the top of AR 21), making findings which Ms. Lean does not otherwise challenge. The ALJ also discussed her complaints of memory loss (beginning on the bottom of AR 25 and continuing on AR 26), and specifically gave only partial weight to the opinions of state agency psychologists because he found greater limits on memory, attention, and concentration were supported by the record (AR 28). The ALJ's opinion clearly demonstrates that he did not ignore any of these symptoms. This Court's role is not to re-weigh the evidence. Oldham v. Astrue, 509 F.3d 1254, 1257-58 (10th Cir 2007). Of course, the Court may overturn the ALJ if his decision “is overwhelmed by other evidence in the record, ” Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004), or if he “mischaracterizes” evidence, Talbot v. Heckler, 814 F.2d 1456, 1464 (10th Cir. 1987). But the Court does not find the evidence cited by Ms. Lean to be so overwhelming such that the ALJ's opinion lacks substantial evidence, and Ms. Lean does not point to any evidence that the ALJ mischaracterized or misapprehended in finding that her headaches do not prevent her from performing light work.

         In reply, Ms. Lean additionally relies on Lauer v. Commissioner, in which the Tenth Circuit remands because “the ALJ did not analyze Ms. Lauer's complaint about near-daily migraine headaches at any step of his analysis.” 752 Fed.Appx. 665, 667 (10th Cir. 2018); see Doc. 23 at 2. In Lauer, the ALJ concluded that the claimant did not have headaches without explaining why. Id. This decision thus has little relevance to this case, where the ALJ did consider whether Ms. Lean's headaches are a disabling impairment and explained (at length) why they are not.

         2. Social functioning

         The ALJ's RFC limited Ms. Lean to “occasional contact with coworkers, supervisors, and the general public.” AR 18. Ms. Lean argues that this limitation is not restrictive enough. Doc. 21 at 15. Ms. Lean asserts that the activities the ALJ relied on to reach this finding-her “ability to use public transit, independent functioning in her activities of daily living, and her ability to go shopping and to a casino”-do not constitute evidence that she can interact with others in the workplace. Doc. 21 at 15-16.

         In support of her argument, Ms. Lean relies on various medical evidence of record. Ms. Lean first argues that the ALJ should have interpreted her November 2016 casino trip to be evidence of psychiatric problems rather than proof that she can function socially. Doc. 21 at 16. She emphasizes that Ms. Lean reported to Dr. Sharon that, during the casino trip in question, she suffered hallucinations and suicidal thoughts. Id.; AR 1237-38. Again, however, the ALJ demonstrated that he considered-and weighed-this same evidence. See AR 24 (“The claimant also endorsed auditory and visual hallucinations at times, such as hearing voices having conversations, strange noises while listening to the radio, and seeing shadows at night.” (citing AR 1255)); AR 25 (“[S]he reported improved psychosis, and described her hallucinations as only occasionally hearing her brother-in-law yell at her when no one is there, and sometimes seeing shadows.” (citing AR 1587)); AR 24 (“Beginning on August 25, 2016, treating psychiatrist Dr. Nathaniel G. Sharon, M.D., to whom the claimant had first presented on February 4, 2016 for hormone replacement therapy, found the claimant to be positive for chronic suicidal ideation, but without intent or plan and with denial of nonsuicidal self-injurious behaviors.” (citing AR 1237, 1246 & 1253)). After discussing this evidence, the ALJ discounted it, noting that “since establishing mental health care, [Ms. Lean] has consistently denied delusions, ideas of reference, paranoid ideation, or grandiosity.” AR 24 (citing AR 1238, [5] 1246, 1342 & 1587). Substantial evidence supports this determination, so the Court does not reweigh this evidence.

         Ms. Lean also challenges the ALJ's finding that she had pleasant and cooperative interactions with providers. Doc. 21 at 16. The ALJ relied on medical reports stating Ms. Lean was cooperative (citing AR 493, 593-94, 846, 871, 900, 1073, 1078, 1107, 1240, 1342 & 1533), pleasant (citing AR 594, 1246 & 1590), calm (citing AR 871 & 1078), friendly (citing AR 1078 & 1200[6]), easy to engage (citing AR 588), and had eye contact that was good or within normal limits (citing AR 588, 900, 980, 1078, 1246, 1342 & 1590). See AR 17.

         Ms. Lean challenges these findings by pointing to treatment records in which providers note that she is anxious and tearful. Id. (citing AR 492-93, 635-39, 680, 867-74, 898, 1072-74 & 1146-48). Again, the ALJ neither ignored nor mischaracterized any of this evidence. The ALJ specifically discussed Ms. Lean's anxiety in the course of several pages of analysis pertaining to psychological impairments (AR 24-26). In fact, the ALJ discussed and cited many of the very same treatment records Ms. Lean claims he “omitted.” For instance:

• “[S]he reported increased anxiety depression and paranoia following a series of distressing events . . . .” AR 24 (citing AR 574, 588, 703, 840, 845 & 1078).
• “On August 29, 2016, she asked Mr. Lujan about service dogs due to anxiety/ depression, but was otherwise stable.” AR 25 (citing AR 1220).
• “On August 26, 2014, she underwent a State Agency mental status examination conducted by Dr. Camellia Clark, M.D. She described her mood as ‘anxious.'” AR 25 (citing AR 680).
• “On a few occasions, she was tearful when discussing her history.” AR 26 (citing AR ...

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