Pamela Meade Sargent
How Judge Sargent decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
An ALJ cannot simply say a medical opinion is 'not supported' without engaging its substance, especially when reviewing psychologists and examiners all agree on the direction of the limitation.
“I find that the ALJ substituted his own judgment for that of mental health professionals by finding that Owens's impairments did not meet or equal the criteria of Section 12.04.”
Crediting a state-agency opinion 'great weight' while ignoring the specific marked or moderate limitations that opinion actually assessed is reversible -- weight assigned in name only does not satisfy the substantial-evidence standard.
“While the ALJ noted that he was giving great weight to the state agency psychologists' opinions because they were consistent with the objective evidence of record, he failed to address the marked and moderate limitations assessed by them.”
An opinion formed without the benefit of later, more complete medical evidence (a new MRI, a new clinical finding) does not outweigh a treating or examining source's opinion just because its bottom line looks more consistent with earlier exam findings.
“the opinions of the state agency physicians, who did not have the benefit of the entirety of the medical evidence, do not constitute substantial evidence to support the ALJ's finding as to Coffey's residual functional capacity”
Under the post-2017 regulations she treats supportability and consistency as two SEPARATE, mandatory factors -- an ALJ who explains why a source's opinion is inconsistent with the record but never addresses whether the source's own findings support the opinion has not done enough, even citing the same evidence for both would not save the analysis.
“the ALJ's evaluation of Dr. Brown and Dr. Kumar's opinions is devoid of any explanation whether he considered the supportability factor in evaluating the persuasiveness of their opinions”
Procedural preferences
She reads the ALJ's own opinion for internal contradiction (e.g. a restriction the ALJ says 'may seem warranted' or the evidence 'might support', followed by a finding that no severe impairment exists) and will remand at step two on that basis alone, without reaching the rest of the sequential evaluation.
“the ALJ's very next sentence is, '[h]owever, [Gardner] has no medically determinable severe impairments that would support these limitations as set forth hereinabove.'”
A symptom that the record shows is reasonably controlled by medication or treatment will not support a disability finding, even where a treating source's diagnosis is otherwise credited.
““If a symptom can be reasonably controlled by medication or treatment, it is not disabling.” Gross v. Heckler, 785 F.2d 1163, 1166 (4th Cir. 1986).”
Cautions
She will affirm the Commissioner where the objective medical evidence genuinely does not support the severity a claimant or treating source alleges, and does not remand merely because a claimant disagrees with how the ALJ weighed the record.
“the ALJ correctly noted that Dr. Rhinehart's findings that Barrett suffered from disabling back pain and disabling depression are not supported by the objective evidence of record”
A claimant's own reported daily activities can undercut a claim of greater limitation than the ALJ found -- she will not remand for a more restrictive residual functional capacity where the claimant's own testimony describes a level of activity inconsistent with the alleged severity.
“Slagle reported she performed various activities, including taking care of her grandparents; running errands; attending a concert; working part-time on a paper route; and changing a tire.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“For the foregoing reasons, Barrett's motion for summary judgment will be denied, the Commissioner's motion for summary judgment will be granted and the Commissioner's decision to deny benefits will be affirmed.”
“For the foregoing reasons, the Commissioner's motion for summary judgment will be denied, the Commissioner's decision denying benefits will be vacated and this case will be remanded to the Commissioner for further development.”
“For the foregoing reasons, the Commissioner's motion for summary judgment will be denied, the Commissioner's decision denying benefits will be vacated, and the case will be remanded to the Commissioner for an award of benefits.”
“For the foregoing reasons, the Commissioner's motion for summary judgment will be denied, Bush's motion for summary judgment will be granted, the Commissioner's decision denying benefits will be vacated, and Bush's claims will be remanded to the Commissioner for an award of benefits.”
“Based on the above, I find that substantial evidence does not exist in the record to support the ALJ's rejection of the opinions of Jarrell regarding the effects of Livesay's mental impairments on her work-related abilities. Therefore, I find that substantial evidence does not support the Commissioner's decision to deny benefits, and I will remand the case to the Commissioner for further consideration.”
“Therefore, while the ALJ might have been justified in disregarding Dr. Joshi's opinions, the opinions of the state agency physicians, who did not have the benefit of the entirety of the medical evidence, do not constitute substantial evidence to support the ALJ's finding as to Coffey's residual functional capacity. Therefore, I will vacate the Commissioner's decision denying benefits and remand for further development consistent with this Opinion.”
“Based on the above, I do not find that substantial evidence exists to support the ALJ's finding that Gardner did not suffer from a severe impairment. An appropriate Order and Judgment will be entered remanding Gardner's claim to the Commissioner for further development.”
“While the ALJ noted that he was giving great weight to the state agency psychologists' opinions because they were consistent with the objective evidence of record, he failed to address the marked and moderate limitations assessed by them. ... Based on my review of the record, I cannot find that substantial evidence exists to support the ALJ's mental residual functional capacity finding.”
“Based on this, I find that substantial evidence exists to support the ALJ's consideration of the medical evidence and his residual functional capacity finding. An appropriate Order and Judgment will be entered.”
“Based on this, I cannot determine that substantial evidence exists to support the ALJ's finding that Hess had the residual functional capacity to perform medium work. ... An appropriate order will be entered remanding this case to the Commissioner for further consideration.”
“Based on this, I cannot find substantial evidence exists to support the ALJ's consideration of the medical evidence and his residual functional capacity finding. An appropriate Order and Judgment will be entered.”
“Based on the above, I find that substantial evidence exists to support the ALJ's weighing of the medical evidence and his residual functional capacity finding. An appropriate Order and Judgment will be entered.”
Caseload & timing
From public federal docket records for this judge.
Median motion-to-ruling time: 216 days (N = 4).
Her civil docket at consent jurisdiction (28 U.S.C. 636(c)) runs from 1994 through at least 2021 and is dominated by Social Security disability appeals (DIB/SSI/DWIB, nature-of-suit codes 863-865), reflecting the disability-heavy caseload of rural coal-country Virginia; a smaller, mostly-1990s cohort of consent civil cases covers prisoner civil-rights suits, a patent case, contract and product-liability diversity suits, and a bankruptcy-withdrawal matter. Social Security appeals filed in 2020-2021 took roughly a year or more to reach a final decision, so a docket snapshot taken shortly after filing can look like the vein had dried up when it had not; the last several she has decided were filed in 2021 and resolved in 2022. Her most recent docket, by contrast, is almost entirely petty-offense and misdemeanor criminal matters -- the routine magistrate criminal duty for the Abingdon Division -- which does not produce the kind of written, quotable dispositive rulings this record tracks.
Put Judge Sargent's record to work
Ezel drafts and answers grounded in this exact profile: how Judge Sargent actually rules, not a generic AI guess.
Opens in Ezel Pro. Every answer is grounded in Judge Sargent's own signed orders and cites them.