Morales v. Secretary

USCA1 Opinion





September 29, 1992 [NOT FOR PUBLICATION]








___________________


No. 92-1246




CARMEN MORALES,
Plaintiff, Appellant

v.

SECRETARY OF HEALTH AND HUMAN SERVICES,
Defendant, Appellee.

__________________


APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

[Hon. Jose Antonio Fuste, U.S. District Judge]
___________________

___________________

Before

Breyer, Chief Judge,
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Campbell, Senior Circuit Judge,
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and Cyr, Circuit Judge.
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___________________

Francisco J. Hernandez-Rentas on brief for appellant.
_____________________________
Daniel F. Lopez Romo, United States Attorney, Jose Vazquez
_____________________ ____________
Garcia, Assistant United States Attorney, and Joseph E. Dunn,
______ _______________
Assistant Regional Counsel, Office of the General Counsel,
Department of Health & Human Services, on brief for appellee.

__________________

__________________




















Per Curiam. Claimant, Carmen Morales, appeals from
__________

a district court decision affirming the denial of her

application for Social Security disability benefits for the

period between September, 1981 and December, 1986. Claimant

alleges mental and physical impairments. The Administrative

Law Judge (ALJ) concluded that, taken together, claimant's

impairments are severe and prevent her from performing her

past work as a cook, but would not preclude her from

performing a significant number of other jobs in the national

economy. We affirm.

BACKGROUND
__________

Claimant was born in 1944 and has a ninth grade

education. She worked as a cook in a school cafeteria until

September, 1981, when her disability allegedly commenced.

She has been unemployed since then. Claimant was granted

disability benefits by the Commonwealth of Puerto Rico

Retirement Systems Administration. Claimant filed an

application for Social Security disability benefits on August

2, 1985, alleging a "nervous condition." Subsequently, she

also alleged poor circulation and pain in her legs and feet.

Claimant's insured status expired on December 31, 1986.

Following denial of her application, claimant obtained a

hearing before the ALJ on October 5, 1987. Following

testimony by the claimant, Dr. Rafael Nogueras, a

psychiatrist, testified as a medical advisor at the request



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of the ALJ. The ALJ concluded that "the combined effect of

claimant's musculoskeletal and mental components amount to a

severe impairment," but that, at the time her insured status

expired, claimant's impairment did not prevent her from

performing her past work as a cook. Therefore, the ALJ

concluded that claimant was not entitled to disability

benefits.

Claimant appealed the ALJ's decision to the district

court, which in an opinion dated July 19, 1989 remanded the

case on the ground that the ALJ gave inadequate consideration

to claimant's complaints of pain in her heels. The district

court faulted the ALJ for failing to properly apply the

guidelines set forth in Avery v. Secretary of Health and
___________________________________

Human Services, 797 F.2d 19 (1st Cir. 1986) for evaluation of
______________

residual functional capacity ("RFC") for subjective

complaints of pain.

On remand, the ALJ conducted a supplemental hearing on

February 8, 1990, at which both claimant and a vocational

expert ("VE") testified. In an opinion dated February 26,

1990, the ALJ modified his original findings and concluded

that claimant's RFC "is limited to a light work level of

exertion, of unskilled, simple nature where she can alternate

positions at will" and, therefore, claimant is unable to

perform her past work as a cook. Based upon the VE's

testimony on the local availability of a significant number



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of jobs which claimant could perform, the ALJ again concluded

that claimant was not entitled to benefits. The Appeals

Council affirmed the ALJ's decision.

Claimant again appealed to the district court on the

ground that there was not substantial evidence to support the

Secretary's decision. The district court concluded that,

with respect to claimant's complaints of pain, the ALJ had

fulfilled the requirements of Avery. The district court
_____

admonished the ALJ, however, for complying with the letter

but not the spirit of the Avery decision and stated that it
_____

would prefer more specific findings supporting the ALJ's

reasoning. Concluding that the Secretary had substantial

evidence to support his finding that claimant was not

disabled, the district court affirmed the denial of benefits.



MEDICAL EVIDENCE
________________

A. Mental Impairment
_________________

The record contains medical reports prepared in

November, 1982 and December, 1983 by treating physicians in

connection with claimant's application for disability

benefits from the Puerto Rico Retirement System. The record

also includes reports from doctors at the Arecibo Mental

Health Center where claimant was treated, on and off, as an

out-patient from January, 1983 through February, 1986. In

addition, the record contains reports from claimant's



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treating psychiatrist, Dr. Llado, and from three consulting

psychiatrists who examined claimant, Dr. Mojica, Dr. Guillen

and Dr. Toro. Finally, the record contains the testimony of

the medical advisor, Dr. Nogueras, a non-examining consulting

psychiatrist who reviewed the claimant's medical records.

In a November, 1982 report, based on monthly

examinations since September, 1981, the examining physician

reported that claimant complained of "insomnia, agitation and

crying spells, apparently without reason." The diagnosis was

"anxiety neurosis with depression." There is no indication

that medication was prescribed for this condition.

The first report from the Arecibo Mental Health Center,

dated January, 1983, describes claimant's symptoms as

follows: "frequent headaches, asphixiation, shortness of

breath, pain in the side of the heart. Says that when she

tries to speak in places where there are groups of people,

she feels her mouth trembles. Cries frequently . . .

Forgetful. Starts screaming because she develops

nightmares." The diagnosis is "anxiety disorder with

depressive traits." The report recommends medical evaluation

and individual therapy.

Subsequent reports from the Mental Health Center visits

for February, April, May and August indicate that the

claimant reported that "the medication" (unspecified) helps

her. In September, 1983, claimant said that the treatment



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had been helping her. In November, 1983, claimant was

discharged from the Center because she indicated that she

wished to continue treatment with a private psychiatrist.

In August, 1984, claimant returned to the Center to

continue treatment. In September, 1984, she "appeared

anxious and depressed. Cried during the interview." In

March, 1985, the report indicates that claimant said she felt

"fair" and that the medication that helped her most was

"Tranxene 7.5 mg HS." In June, 1985, she said that the

medication still helped her, but that after she stopped

taking hormones prescribed following her recent hysterectomy,

she developed "flushes" and became nervous. In September,

1985, claimant reported that "sometimes she starts screaming

without any reason" and that she now takes her medication

twice a day. The report from the claimant's November visit

indicates that "on some days she feels better, others she

feels worse," that she still takes her medication twice a day

and that it helps her. The report from her December, 1985

visit indicates that she "appears depressed." Claimant

indicated that she "feels controlled only with the use of the

medication" and that she "doesn't tolerate being in groups of

people, tends to isolate herself." Finally, in her last

visit (February 1986) to the center during the relevant

period, claimant stated that she felt "fair" but that her

application for Social Security benefits caused her to feel



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nervous. She also complained of "tachicardia" and that her

heart "trembles." Claimant indicated that the medication

helps her.

On August 27, 1985, claimant was examined by Dr. J. A.

Mojica Sandoz, a psychiatrist, for the purpose of evaluating

her eligibility for Social Security disability payments. At

the interview, claimant admitted upon questioning to

experiencing "insomnia, headaches, dizzy spells and moments

of easy irritability." She reported that she was taking

Tranxene 7.5 at bedtime but that "they don't do anything to

me." The report also indicated that claimant was taking

analgesics. Claimant reported that she lives with her

employed husband and teenage son and that she does the

household chores (except for the shopping).

Dr. Mojica reported that he "could not detect anything

remarkable regarding her attitude or behavior. She answered

every question asked." He added that "she was slightly

anxious and tense" and that "the affectivity prevailing

during the examination was of a depressive nature," but that

she was "accessible, cooperative and frank. . . The progress

of her thought was of a normal tempo. She was spontaneous

and expressed herself in a logical, lucid, coherent and

relevant form." She did not exhibit any difficulty with

establishing interpersonal relations. Her "capacity for

remote, intermediate and recent memory was adequate." She



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was normally oriented in time, place and person. Her

capacity for judgment was "adequate," and she was "mentally

competent to handle her funds in an adequate and rational

manner." Dr. Mojica's diagnosis was of a mild dysthymic

disorder. The secondary diagnosis was of a histrionic

personality disorder.

The first report of Dr. Victor J. Llado, claimant's

treating psychiatrist, is dated September 3, 1985. Claimant

had been receiving psychiatric treatment from Dr. Llado since

October, 1983. Dr. Llado describes claimant's symptoms as

follows: "a combined picture of depressive states and anxiety

attacks, including mild-to-moderate insomnia, overall feeling

of nervousness, sadness, tiredness, and aloofness." Claimant

reported to Dr. Llado that she stays home most of the day,

doesn't handle any money and has handed over all

responsibilities to family members. She denied "doing any

chores or engaging in any tasks or meaningful activities at

home." (In contrast to Dr. Llado's picture of inactivity

however, was claimant's own description of functions in her

August 1985 application where she said she took care of

household chores, did the cooking, went shopping with her

husband, and did some gardening.)

Dr. Llado's report contains the following description of

claimant's mental status: "The claimant was alert, well

oriented as to time, place, and person"; "The claimant's



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social judgment and reality testing seemed intact"; "The

claimant's thought processes were intact"; "The content was

appropriate, relevant, simple, scanty, but commensurate with

the claimant's socio-demographic characteristics." There was

no evidence of perceptual disturbances or memory deficits.

Dr. Llado reported that claimant wept from time to time

during the meeting and evidenced a "mild-to-moderate level of

psychomotor retardation" and "easy distractibility with poor

concentration throughout the meeting."

Dr. Llado diagnosed claimant as having a chronic, severe

generalized anxiety disorder. The doctor concluded that

"claimant's emotional condition is rather severe" and that

the prognosis is poor. In his opinion, claimant's emotional

condition, including a "poor sense of self," seriously limits

the claimant and makes her very vulnerable to the ordinary

stresses of employment. He felt she could not "meet the

occupational and performance levels demands of a regular

competitive job market."

Dr. Llado's second psychiatric report is dated March 25,

1986. ( He saw claimant four times during the intervening six

months between his first and second reports.) The symptoms

remained the same: "tiredness, insomnia, mild crying spells,

feeling sad and lonely, and overall emotional dependency."

Dr. Llado reported that he had been treating claimant with

Xanax 1 mg. h.s.p.o. and psychotherapy. Claimant's daily



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activities remained limited: "The claimant tends to avoid

responsibilities assuming a passive-dependent posture at

home." The report added that "most tasks and chores are

performed by others" and that "decision making within the

family is done with little or no participation by claimant."

The report described claimant's mental state in similar

terms as Dr. Llado's previous report, but added that "the

claimant seemed very anxious, easily startled, complaining of

inability to relax, dry mouth, and restlessness." The

diagnosis remained the same as the previous report. In his

discussion of the diagnosis, however, Dr. Llado stated that,

in addition to a poor sense of self, claimant suffered from

"concretist thinking, simplistic behavior, labile affect, and

easy irritability." He concluded that "the excessive anxiety

and extreme degree of social isolation have created a poor

tolerance for stress and inability to relate well to others."

On February 2, 1986, claimant was evaluated by Dr. Juan

A. Guillen, an examining physician. She complained that she

constantly felt like crying, that she did not want to see

people or to be there and that she wants to work. Her

husband reported that she screams at night, that everything

irritates her and that she has to be supervised in taking her

medications. She was being treated with Tranxene 7.5 mg.

H.S. She did, however, visit with neighbors and within the

family.



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Dr. Guillen described claimant as possessing psychomotor

retardation, but adequate motor coordination. He reported

that she was cooperative and established a rapport with him

during the evaluation, although it was not spontaneous. She

did not respond to the doctor's initial greeting, avoided

visual contact, answered only some of his questions and cried

during the interview when talking about her complaints. The

report then described claimant as sad, with slow speech, but

as possessing "adequate association of ideas, the sequence

was logical, coherent and relevant." Dr. Guillen reported

that claimant's affect was "appropriate to the content of her

thoughts. She was alert, with adequate attention, in contact

with reality. She was oriented in person and place,

partially in time. Her memory for past events, recent and

immediate were adequate."

The record also contains a psychiatric report by Dr.

Toro dated February 7, 1987, more than a month after

claimant's insured status expired. Claimant reported that

she was seeing Dr. Llado each month and taking the following

medications: Tranxene 3.75 mg. 1 A.M., Tranxene 15 mg. 1 hs.

The report stated that claimant's "response to treatment has

been good." The claimant described a life of relative

isolation, leaving her home only for her medical

appointments, and inactivity, helping some with household





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chores. Claimant reported a decreased ability to do simple

tasks and a decreased tolerance to stress.

Dr. Toro described claimant's behavior during the

examination: "She cried frequently during the interview. . .

Her eyes had a sad expression. She did not make good eye

contact. Her look was directed towards the wall and the

floor. Her speech was spontaneous and she spoke in a whining

tone of voice." The report concluded that claimant was

"coherent, logical and relevant and associated well in her

ideas. . . Her behavior was cooperative." It also found that

claimant "seemed to be preoccupied," looked sad, acted

depressed and anxious. "She was oriented in person, in place

and not oriented in time as she did not even know the year."

Dr. Toro described claimant's remote memory as deficient,

though not her short term or recent memory. He found her

attention span to be adequate, but her concentration

deficient. The diagnosis was dysthymic disorder with

anxiety.

On February 18, 1987, Dr. Luis Sanchez Raffuci, a

psychiatrist, completed a Psychiatric Review form and a

Mental Residual Functional Capacity Assessment form based

upon his examination of claimant's medical records. He

concluded that claimant suffered from an "affective disorder"

characterized by "depressed mood, poor motivation, somatic

preoccupations and diminished concentration." Dr. Sanchez



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determined that the severity of claimant's impairment did not

meet or equal the ones listed in 20 C.F.R. Part 404, Subpart

P, Appendix 1 and did not prevent her from performing

substantial gainful activity.

Dr. Sanchez' assessment of claimant's mental functional

capacity was that claimant's ability to remember detailed

instructions was moderately limited by her depressed mood and

diminished concentration, but that the other functions in the

"understanding and memory" category were preserved. He

reported that she was markedly limited in her "ability to

carry out detailed instructions," and moderately limited in

her ability to "maintain regular attendance and complete a

normal work week without interruptions." In terms of "social

interaction," Dr. Sanchez determined that most functions were

preserved, but that her depressed mood and poor motivation

moderately limited her "ability to interact appropriately

with the general public and the ability to respond

appropriately to criticisms from supervisors." In the

"adaptation" category, all claimant's functions were

preserved.

At the first hearing before the ALJ, Dr. Nogueras

summarized the claimant's medical records and gave his

opinion of claimant's condition. He noted that although Dr.

Llado's September, 1985 report diagnosed claimant as having a

"severe and chronic" condition, Dr. Llado's description of



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claimant's mental state was of a condition that was only

"slight to moderate" in intensity. Dr. Nogueras referenced

the list of claimant's adequate functioning factors included

in Dr. Llado's report. In response to questioning by the

ALJ, Dr. Nogueras concluded that claimant suffered from a

dysthymic disorder of moderate intensity. He added that the

condition has worsened over the relevant period, increasing

from slight to moderate intensity. On cross examination, Dr.

Nogueras confirmed that claimant's mental condition did not

meet or equal the mental impairments included in the

Secretary's Listing. He stated that claimant's crying spells

during the interviews implied an emotional variability which

"if this was her usual behavior in a work environment" might

present an obstacle in terms of her job performance.

The record also includes a letter from Dr. Elias Jimenez

Olivo, dated February 17, 1990 and submitted at the time of

the supplemental hearing. Dr. Jimenez' treatment of claimant

began on November 14, 1987, almost one year after claimant's

insured status had expired. He concluded that claimant's

symptoms "are compatible with a diagnosis of Chronic

Dysthymic Disorder" and that she was taking the following

medication: Limbitrol 10-25 H.S. and Elavil 10 mgs. bid. Dr.

Jimenez' opinion was that claimant was "not fit to engage in

any type of sustained and substantial gainful activity."

B. Physical Impairment
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Claimant's 1985 application for disability benefits did

not base disability on any physical problems. A nervous

condition alone was described as the disabling condition. In

claimant's Reconsideration Disability Report dated February,

1986, however, she reports that since 1981, she has had a

"leg problem with bad circulation, and 'espuelones' in both

feet" and that she "can't stay too long standing or walking."

In March, 1980, claimant consulted doctors at the State

Insurance Fund (SIF) regarding pain in her right lower leg

and foot and numbness in her middle toe, which she had been

experiencing intermittently over the past four to five years.

Laboratory tests and x-rays of the right leg and foot were

normal. Claimant apparently returned to the SIF doctors in

July, complaining of pain in her right leg, including her

knee. She was referred to Dr. Rolando Colon Nebot, an

orthopedist. All tests indicated that the leg was normal and

found no evidence of osteoarthritis and no edema or effusion

of claimant's right knee and range of motion within normal

limits.

In the reports prepared in connection with claimant's

application for state disability benefits, claimant was

diagnosed first with arthritis in her right knee and

circulation problems, by Dr. Valazquez, who treated claimant

between October, 1978 and March, 1980. A second report was

prepared by a doctor (name illegible) who treated claimant



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from September, 1981 through November, 1982 for "pain in both

heels." The diagnosis was of bilateral calcaneus spurs.

That report stated that the "condition does not improve with

the use of prosthetic shoes nor with the injection of

steroids or analgesics, only improvement is with rest." The

physician noted that the claimant "can't remain standing over

1/2 hour continuously due to the pain in the heels."

Finally, Dr. Coker reported that he treated claimant from

August, 1982 through November, 1982. The diagnosis was also

of calcaneal spurs in both heels. Dr. Coker reported

prescribing analgesics and recommending weight loss. There

was "no improvement" in response to the treatment.

Dr. Sandoz's psychiatric report indicated that claimant

complained of "pains in both lower extremities." Claimant

added that "those pains started very slowly and gradually

they increase in intensity. I feel pains in my legs and then

I began to feel dizzy spells especially when I am in crowded

places." Dr. Sandoz reported that claimant's "gait was

normal" when he met with her on August 27, 1985.

Dr. Llado's first report indicated that "claimant

allegedly developed an emotional condition as a result of a

work-related accident in 1981 when she developed edema of

legs due to standing too long as a dining room worker." He

noted that claimant had complained of "persistent, severe leg

pains, secondary to phlebitis treated by Dr. Labad."



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The record includes a report by Dr. Miguel A. Marrero

Bonilla, an orthopedic surgeon, who examined claimant on July

31, 1986 at the request of the Disability Determination

Services. The report indicated that claimant feels pain in

her heels when she stands up or walks long distances. Based

upon his physical examination of claimant, Dr. Bonilla

reported that claimant, who "has marked obesity," walks

normally but "sits and squats with difficulty on account of

the obesity." He further reported that she had good range of

motion in her hips, knees and ankles. The report concluded

as follows: "The patient has calcaneal spurs in both heels.

X-rays showed in the right os calcis. There is good R.O.M.

of the right knee. No swelling."

At the supplemental hearing on remand, the ALJ

questioned claimant about the pain in her legs. She

testified that it began in the right leg but later spread to

both legs, and emanates from her feet to her hips. Claimant

stated that she was taking Motrin 800 and Flexeril, as

prescribed by Dr. Soberal, her treating physician. The ALJ

also questioned claimant about her daily activities. She

stated that she cooks, with her daughter's help, and washes

clothes.

Miguel A. Pellicier, a VE, also testified at the

supplemental hearing. He stated that claimant's former job

as a cook was "medium" in terms of physical demand, involving



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constant standing and walking. It was a skilled job, but at

a low level. The ALJ asked the VE to assume that claimant

only has the residual mental capacity for simple non-skilled

work, but that she is capable of paying attention and

concentrating. The ALJ further assumed that claimant's pain

in her legs prohibits her from being on her feet all day and,

therefore, that she is limited to light work which permits

her to alternate positions at her discretion.

Given those assumptions, the VE concluded that claimant

could perform the following jobs: garment folder, garment

bagger, garment turner, classifier of cut pieces. Mr.

Pellicier testified that these jobs exist in the national and

local economy. He further stated that other jobs exist which

claimant could perform, even if she was required to do

sedentary work. In response to the ALJ's questioning, Mr.

Pellicier stated that, in general, pain which is severe and

frequent affects one's capacity to concentrate and pay

attention to tasks performed.

DISCUSSION
__________

On appeal, claimant argues that the Secretary's decision

is not supported by substantial evidence. Claimant further

contends that her due process rights were violated because

the ALJ failed to follow the proper procedures with respect

to the following: 1) the evaluation of her disability under

the steps set forth in 20 C.F.R. 404.1520 (1991), 2) the



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evaluation of complaints of pain required by Avery v.
_________

Secretary of Health and Human Services, 797 F.2d 19 (1st Cir.
______________________________________

1986), and 3) the procedure for evaluating mental impairments

set forth in 20 C.F.R. 404.1520(a).

The Social Security Act establishes the following

standard of review in this case: "[t]he findings of the

Secretary as to any fact, if supported by substantial

evidence, shall be conclusive, . . ." 42 U.S.C. 405(g).

Therefore, the Secretary's decision to deny claimant

disability payments in this case must be affirmed "if a

reasonable mind, reviewing the evidence in the record as a

whole, could accept it as adequate to support his

conclusion." Rodriguez v. Secretary of Health & Human
_______________________________________________

Services, 647 F.2d 218, 222 (1981).
________

The ALJ correctly followed the sequential steps set

forth at 20 C.F.R. 404.1520. He first found that the

claimant had not worked since September, 1981. Second, he

determined that the combined effect of claimant's mental and

physical impairments amounted to a severe impairment. The

ALJ next concluded that claimant did not have an impairment

or combination of impairments that meets or equals the

impairments listed in Appendix 1, Subpart P of the Social

Security Regulations. Fourth, he found that claimant's

impairments prevented her from performing her past relevant

work as a cook. Claimant does not dispute any of the



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above findings. She takes issue, however, with the ALJ's

finding at step five of the sequence, that her impairments do

not prevent her from performing any other work in the

national economy. Specifically, the ALJ found that claimant

had the RFC, physically, to perform light work which allows

her to alternate positions at will. He further found that

claimant had the REC, mentally, to perform work of an

"unskilled, simple nature."

Considering claimant's age at the time that her

insurance expired (42 years), her limited education and her

lack of acquired work skills which are transferable to

skilled or semi-skilled employment, the ALJ found that "there

are a significant number of jobs in the national economy

which [claimant] could perform." The ALJ was assisted in

this determination by Rule 202.18, Table No. 2, Appendix 2,

Subpart P of the Social Security Regulations and by the

testimony of a VE. The ALJ concluded that the claimant was

not disabled within the meaning of the Social Security Act at

any time through December 31, 1986, the date on which

claimant's insured status expired.

The ALJ's findings are supported by substantial

evidence. First, the ALJ's determination that claimant had

the RFC, mentally, to perform unskilled work of a simple

nature is supported by the record. Social Security Rule No.





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85-15 describes the mental demands of unskilled work as

follows:

the abilities (on a sustained basis) to understand,
carry out, and remember simple instructions; to respond
appropriately to supervision, coworkers, and usual work
situations; and to deal with changes in a routine work
setting.


Although there is conflicting evidence on the effect of

claimant's mental impairment on her functional capabilities,

the resolution of such conflicts is for the ALJ. See, e.g.,
_________

Rodriguez v. Secretary of Health & Human Services, 647 F.2d
___________________________________________________

at 222. The records of claimant's treatment at the Arecibo

Mental Health Center from 1983 through 1986 indicate that her

medication, Tranxene 7.5 mg., helps alleviate claimant's

symptoms of anxiety and depression. Dr. Mojica found the

claimant to be accessible, cooperative and frank. She was

"spontaneous and expressed herself in a logical, lucid

coherent and relevant form." Her capacity for memory and

judgment were adequate and she was competent to handle her

funds rationally.

Dr. Llado described his patient as alert, well-oriented,

with social judgment, reality testing and thought processes

"in tact". Dr. Guillen's examination of claimant yielded a

report of adequate motor coordination, association of ideas,

attention and memory. He described claimant as alert, "in

contact with reality", and oriented in person and place. Dr.

Toro found that claimant's "response to treatment has been


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good." He described her as "coherent, logical and relevant

and associated well in her ideas. Her behavior was

cooperative." He determined that her short-term and recent

memory and her attention span were adequate. Dr. Sanchez

concluded that the severity of claimant's mental impairment

"doesn't meet or equal the listings and doesn't preclude

[substantial gainful activity]."

To be sure, as recounted earlier, there was

conflicting evidence. In particular, both of claimant's

treating psychiatrists expressed doubt regarding claimant's

ability to meet the demands of ordinary, gainful employment.

Dr. Llado was concerned that claimant's emotional condition

made her very vulnerable to the ordinary stresses of

employment. Dr. Jimenez, based upon his treatment of

claimant between November, 1987 and February, 1990, concluded

that she "is not fit to engage in any type of sustained and

substantial gainful activity."

The record taken as a whole, however, provides

substantial evidence to support the ALJ's conclusion that

claimant is capable of performing work of an unskilled,

simple nature. It was within the ALJ's discretion to

determine that, despite the moderate limitations upon certain

of claimant's functional abilities, the mental demands of

simple work are within her capabilities. Given the support

for this conclusion in the record, the ALJ was entitled to



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reject the contrary opinions of Dr. Llado and Dr. Jimenez.

Dr. Nogueras testified that Dr. Llado's diagnosis of a

"severe and chronic condition" was contrary to his

description of a condition that was only slight to moderate

in intensity. Dr. Jimenez' opinion that claimant was not fit

to work was unaccompanied by medical analysis and was based

on treatment which began after claimant's insured status had

expired.

At the October, 1987 hearing before the ALJ, Dr.

Nogueras stated that if the reports of frequent crying

contained in the record represent claimant's "normal behavior

in a work environment," this could present an obstacle to

claimant's ability to perform a job. The ALJ did not

include this characteristic, however, in describing claimant

to the VE at the February, 1990 hearing. Although there was

conflicting evidence, the ALJ's apparent conclusion that

frequent crying would not be claimant's ordinary behavior in

a work environment is supported by the record.

In her 1985 Disability Application, claimant describes

a fairly active routine, including household chores, cooking,

shopping with her husband and some gardening. This suggests

that claimant was not incapacitated by her crying spells.

The report of her behavior at the original interview with the

Social Security Administration in 1985 does not indicate that

claimant cried. In all of her visits to the Arecibo Mental



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Health Center from January, 1983 through February, 1986,

claimant is reported to have cried only during her September,

1984 visit. Finally, at her August, 1985 appointment with

Dr. Mojica, claimant is not reported to have cried.

Second, the ALJ's conclusion that claimant is capable of

a light work level of exertion provided that she can

alternate positions at will is also supported by substantial

evidence. The medical records are consistent in their

diagnosis of calcaneal spurs in claimant's heels. Taking

account of this diagnosis and claimant's complaints that she

feels pain in her heels when she stands up or walks long

distances and that she is unable to stand for more than one-

half hour at a time, the ALJ indicated that claimant cannot

perform the full range of light work and must be permitted to

alternate positions at will. The VE testified that jobs

existed in the national and local economy for a person with

claimant's limitations. The VE further testified that even

if claimant was limited to sedentary work, there were jobs

that she could perform in the national and local economy.

Avery v. Secretary of Health and Human Services, 797
___________________________________________________

F.2d 19 (1st Cir. 1986) interprets the Social Security

Administration's current policy as requiring that "when there

is a claim of pain not supported by objective findings, the

adjudicator is to 'obtain detailed descriptions of daily

activities by directing specific inquiries about the pain and



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its effects to the claimant, his/her physicians from whom

medical evidence is being requested, and other third parties

who would be likely to have such knowledge.'" Avery. 797 F.2d
_____

at 23. This directive has been satisfied in this case.

At the February, 1990 hearing, claimant was questioned

about her former employment and she described in detail the

tasks that she performed. She also described her symptoms of

pain. The ALJ questioned claimant about her daily

activities, when she began to be treated for her pain, the

location and severity of the pain, and how the location and

severity of the pain had changed over time. The medical

records include reports containing descriptions by claimant

of her pain and the ways in which it limits her activities.

The ALJ considered these reports, but also noted that

the objective medical evidence was inconsistent with a

finding of disabling pain. The examination by Dr. Marrero,

an orthopedist, "has not shown the presence of any swelling,

inflammation or marked range of motion limitation of right

knee" the ALJ reported in his February, 1990 opinion. He

further noted that "[t]he claimant was treated with

analgesics which does not show the presence of any disabling

pain." Finally, he noted that claimant was "not observed in

any pain" and that she reported involvement in daily chores,

including cooking and shopping. These findings are

substantially supported by the record as a whole.



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The ALJ found the claimant's complaints credible only

"to the extent that [claimant] is limited to a light work

level of exertion." This credibility determination is

entitled to deference. Frustaglia v. Secretary of Health and
_____________________________________

Human Services, 829 F.2d 192, 195 (1st Cir. 1987). The ALJ,
______________

taking account of the diagnosis of calcaneal spurs,

determined that claimant was further limited because "it is

not advisable that she stays walking or standing for

prolonged periods." The ALJ's efforts to obtain information

about claimant's subjective complaints of pain and his

consideration of those complaints were sufficient to satisfy

the Avery standard. See Berrios Lopez v. Secretary of HHS,
_____ ___ __________________________________

951 F.2d 427, 429 (1st Cir. 1991) (ALJ adequately considered
___

claimant's subjective complaints of pain where he relied upon

diagnosis of mild effusion with no edema and good range of

motion in all joints and observation that claimant did not

appear to be in pain at the hearing, but gave "some credence

to her complaints . . . and [found] that the range of light

work she is able to perform is somewhat narrowed.")

CONCLUSION
__________

The ALJ's decision is supported by substantial evidence.

The medical records of the examining psychiatrists, and the

testimony of the medical advisor, support the ALJ's

determination that claimant's mental impairment does not

preclude her from performing work of an unskilled, simple



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nature. The medical evidence also supports the ALJ's finding

that claimant is limited to light work in which she can

alternate positions at will. The ALJ adequately considered

claimant's subjective complaints of pain in determining her

RFC. Finally, the VE's testimony that a significant number

of jobs exist in the national economy which meet the

claimant's requirements provides substantial support for the

ALJ's decision that claimant was not "disabled" under the

Social Security Act. There is no merit to the appellant's

claims that the ALJ failed to follow the proper procedures in

evaluating her disability and her complaints of pain.

Affirmed.
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