Reported / Citable
Background
Jesus G. sought judicial review after the Commissioner of Social Security denied his application for Supplemental Security Income. He alleged disability beginning February 20, 2023, and also filed an application for disability benefits. Following a May 2025 hearing, an administrative law judge found him not disabled, and the Appeals Council denied review.
The ALJ found severe impairments consisting of major depressive disorder, generalized anxiety disorder, panic disorder, and substance use disorder. The ALJ nevertheless concluded that Gonzales could perform work at all exertional levels, subject to nonexertional restrictions limiting him to detailed but noncomplex instructions, occasional interaction with others, and occasional workplace changes. Relying on vocational-expert testimony, the ALJ found that he could work as a motor-vehicle assembler, floor waxer, or hand packager.
Gonzales argued that the ALJ’s symptom assessment violated applicable regulations and Social Security Ruling 16-3p. He asserted that the ALJ improperly relied on minimal daily activities, inadequately considered medication side effects, and failed to account for changes or increases in his medications.
The Court’s Holding
Magistrate Judge Karen Betancourt recommended affirming the Commissioner’s decision because the ALJ applied the governing standards and the denial of benefits was supported by substantial evidence. The report and recommendation emphasized that the court could not reweigh the evidence, resolve evidentiary conflicts, or substitute its judgment for the Commissioner’s.
The magistrate judge concluded that the ALJ did not rely solely on Gonzales’s daily activities. The ALJ also considered psychiatric screenings, acknowledged moderate mental limitations, and incorporated restrictions addressing noncomplex work, social interaction, and workplace changes into the residual functional capacity.
The magistrate judge further found that the ALJ adequately addressed medication side effects and treatment history. Treatment notes did not document the alleged tremors or abnormal movements, Gonzales often denied side effects to providers, and the ALJ characterized his medication management and counseling as routine or conservative treatment that provided some symptom relief. The report therefore recommended affirmance and closure of the case, subject to the parties’ opportunity to object.
Key Takeaways
- The ruling is a report and recommendation from a magistrate judge, not a final judgment adopting the recommendation.
- An ALJ may consider daily activities as part of a broader symptom assessment when the decision also evaluates clinical findings, treatment records, and acknowledged functional limitations.
- Conflicts between a claimant’s testimony about medication side effects and treatment notes are for the ALJ to resolve when the resulting findings are supported by substantial evidence.
Why It Matters
The recommendation illustrates the deferential nature of federal review in Social Security cases. A claimant’s alternative interpretation of the record does not warrant reversal when the ALJ explains the evidentiary basis for the decision and substantial evidence supports it.
For practitioners, the opinion also underscores the importance of treatment records documenting medication side effects and showing how symptoms or treatment changes produce work-related limitations. Because the ALJ addressed each challenged category of evidence, the magistrate judge found a sufficient logical connection between the record and the denial of benefits.