Allen v. Berryhill
273 F. Supp. 3d 763
| M.D. Tenn. | 2017Background
- Allen applied for Disability Insurance Benefits alleging disability from January 20, 2010; ALJ found her not disabled through her date last insured (Dec. 31, 2012) and denied benefits; Appeals Council denied review; district court reviewed the final SSA decision.
- ALJ found severe impairments including depression, anxiety, PTSD, and assigned an RFC for light work with specific environmental and mental limitations.
- Treating psychotherapist Dr. Daniel Wood (five years, 100+ visits) opined marked/serious limitations (GAF ~50) including poor sustained concentration, inability to complete a normal workday/week, and significant social/ stress limitations.
- Two non‑treating doctors: Dr. Loftin (consultative examiner, one visit) and Dr. Phay (state‑agency reviewer, record review) found mild–moderate cognitive/attentional limitations and supported more moderate restrictions; both gave opinions the ALJ credited.
- ALJ gave Dr. Wood’s opinions “no significant weight,” citing lack of objective support, inconsistency with other doctors, Allen having worked during the symptom period, and reliance on subjective complaints.
- District court reversed and remanded, holding the ALJ failed to follow the treating‑physician rule (20 C.F.R. § 404.1527(c)(2)) and did not give adequate “good reasons” for discounting Dr. Wood’s opinion; error was not harmless.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly weighed treating psychiatrist/psychotherapist opinion | Allen: ALJ failed to give controlling weight or good reasons for discounting Dr. Wood, a long‑term treating mental health provider | Commissioner: ALJ permissibly discounted Dr. Wood because records and other experts conflict and opinions relied on subjective complaints | Court: ALJ failed to apply required § 1527(c) factors and give specific, good reasons; remand required |
| Whether inconsistencies cited by ALJ justified rejecting treating opinion | Allen: ALJ mischaracterized record (single‑visit exams don’t rebut longstanding treating observations) | Commissioner: Other medical opinions and objective findings support ALJ’s weight decision | Court: ALJ’s reliance on limited evidence (two interviews, single‑examining and non‑examining reviewers) insufficient and inconsistently applied; many findings overlapped, so discounting was unsupported |
| Whether ALJ’s rejection was harmless error | Allen: Error affected RFC and disability conclusion, so not harmless | Commissioner: Even if procedural error, substantial evidence supports outcome | Court: Error not harmless — Wilson exceptions inapplicable; remand required for proper analysis |
| Whether ALJ improperly discounted mental health opinions as "subjective" | Allen: Mental health diagnoses rely on subjective report; rejecting for that reason is improper | Commissioner: ALJ may consider subjectivity in weighing evidence | Court: ALJ’s rationale that Dr. Wood relied mostly on subjective complaints is legally insufficient for mental health opinions; cannot be sole basis to reject treating opinion |
Key Cases Cited
- Miller v. Comm’r of Soc. Sec., 811 F.3d 825 (6th Cir. 2016) (standard: substantial evidence review and requirement to follow agency rules)
- Buxton v. Halter, 246 F.3d 762 (6th Cir. 2001) (definition of substantial evidence)
- Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (treating‑physician rule and "good reasons" requirement)
- Hensley v. Astrue, 573 F.3d 263 (6th Cir. 2009) (ALJ may not discount treating opinion simply because another source disagrees)
- Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (failure to explain weight given to treating opinion undermines substantial‑evidence support)
- Key v. Callahan, 109 F.3d 270 (6th Cir. 1997) (role of record evidence in substantial evidence review)