Amanda Arnold Sansone

In Estrada Fontanez v. Commissioner of Social Security, Sansone affirmed the benefits denial. She held that the treating provider's recommendation to elevate the claimant's legs was a treatment recommendation, rather than a medical opinion under the revised regulations, and found no basis to add a leg elevation limit to the residual functional capacity.

“the treatment recommendation does not constitute a ‘medical opinion’ as contemplated by the revised Social Security Regulations governing the articulation of medical opinions for claims filed on or after March 27, 2017.”

Substantial-evidence deference: declines to reweigh the record or substitute judgment for the Commissioner's, affirming the RFC and the ALJ's reliance on vocational-expert testimony where supported, 'even if the evidence preponderates against the decision.' An argument that the record 'could support a different RFC determination' is outside the scope of review.

“Ms. Estrada Fontanez's argument here is, in essence, that there is evidence in the record that could support a different RFC determination. This is outside of the scope of this court's review.”

Mental-health opinion evidence: ordinary observations such as proper grooming, cooperation, and intact cognition do not necessarily conflict with severe anxiety, agoraphobia, or panic attacks. When discounting an examiner, the ALJ must connect the cited evidence to the claimed inconsistency and address material examination notes rather than focusing only on a benign mental-status snapshot.

“The ALJ focused mostly on the mental status evaluation and largely ignored Dr. Malowitz’s other examination notes”

Record development: a further consultative examination is not required merely because an existing examiner did not supply a functional-capacity statement. Sansone asks whether the existing testimony, reports, medical records, and agency findings were sufficient for an informed decision.

“Because the record contains sufficient evidence for the ALJ to make an informed decision, the ALJ was not required to order a consultative examination.”

Veterans Affairs disability evidence: when the older Social Security rules apply, identifying differences between the two agencies' standards is not enough. The administrative law judge must meaningfully analyze the rating and its supporting evidence rather than dismissing it in generalized terms.

“The ALJ failed to demonstrate that he considered Ms. May’s VA disability rating with sufficient scrutiny. This failure warrants a remand.”

Medical-opinion articulation: summarizing an opinion does not substitute for explaining both supportability and consistency. A decision that omits either relationship may require remand even when the administrative law judge discusses the medical source elsewhere.

“the ALJ failed to comply with the regulation when considering Dr. Goldstein’s opinion and the decision is not supported by substantial evidence.”

Record-development failures are material when promised prior-application evidence is withheld from counsel and the remaining record contains medical gaps. Sansone requires a record complete enough for counsel to review and for the agency to make a fair assessment.

“the ALJ failed to fully and fairly develop the record, and the evidentiary gaps in the record result in unfairness.”

Headache claims require an express evaluation of frequency, duration, severity, treatment, and the other criteria identified in the governing agency ruling. A conclusory reference to the ruling does not permit meaningful judicial review.

“The ALJ’s decision provides no discussion about Ms. Harris’s headache frequency, duration, or severity in accord with SSR 19-4p.”

In Monette v. Commissioner of Social Security, Sansone remanded after finding that treatment records describing seizures contradicted the administrative law judge's statement that prescribing doctors had received few or no reports of medication side effects.

“Upon review, the record contains multiple reports of seizures to physicians in record.”

Futile amendment after a legally defective theory: in a consent consumer-credit case, Sansone dismissed with prejudice where all seven claims depended on a repeatedly rejected theory and the pleaded statutory and common-law elements independently failed.

“It would be futile to allow Mr. Zickafoose to amend his complaint.”

Rule 26(b)(4)(E) required a reasonable fee for expert discovery but did not require advance payment in Janev. Sansone deferred payment until after the expert responded and testified, and directed the parties to confer on a reasonable amount.

“Thus, prepayment of expert fees is inappropriate at this stage.”

In Ziegler, Sansone partly granted a warrant-production motion, narrowing its time range. She kept production costs with the City despite the City’s need to use the County’s searchable filing system.

“does not justify shifting any part of the expense of production from the City to the plaintiffs.”