Anderson v. Colvin, 1:17-cv-00175

Plaintiff James Anderson, Jr. sought SSI, alleging disability beginning April 19, 2013; ALJ denied benefits after a June 15, 2015 hearing and the Appeals Council declined review.
ALJ found severe impairments: status-post fractured cervical spine, cervical surgery, cervical stenosis, and right upper-extremity radiculopathy.
ALJ assessed an RFC for light work with limitations: lift 20/10 pounds, stand/walk/sit 6 of 8 hours, frequent stooping/crouching, occasional right-sided reaching/overhead and occasional right-sided push/pull.
ALJ relied on medical records, consultative examiner Dr. Tuwiner, State agency opinions, the claimant’s statements about activities (including weightlifting and self-care), and VE testimony to find jobs available (e.g., Office helper).
Plaintiff appealed, arguing (1) the ALJ improperly evaluated his credibility/subjective pain statements and (2) the RFC was flawed (mischaracterized Dr. Tuwiner and ignored bilateral symptoms).
Magistrate Judge Gallagher denied plaintiff’s motion, granted the Commissioner’s motion, and affirmed the ALJ’s decision as supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Credibility evaluation	ALJ failed to identify which of Anderson’s symptom statements were discredited and relied improperly on lack of objective evidence	ALJ properly considered the whole record (objective evidence, daily activities, statements to doctors, work history) per SSR 96-7p	Held for Commissioner: ALJ adequately cited inconsistent statements (e.g., weightlifting, independent ADLs) and objective evidence to discount credibility
RFC assessment	ALJ mischaracterized Dr. Tuwiner (regarding frequency of stooping/crouching) and failed to account for bilateral upper-extremity symptoms	RFC is supported: Dr. Tuwiner’s opinion and objective findings align with light-work RFC; any misstatement about frequency of stooping is harmless because the chosen jobs (Office helper) fit the limitations	Held for Commissioner: ALJ’s RFC supported by medical evidence and state opinions; mischaracterization was harmless error

Craig v. Chater, 76 F.3d 585 (4th Cir.) (substantial-evidence standard governs review)
Lewis v. Berryhill, 858 F.3d 858 (4th Cir.) (ALJ may not discredit pain statements solely for lack of objective support; must explain which statements are discounted)
Monroe v. Colvin, 826 F.3d 176 (4th Cir.) (RFC must include narrative discussion linking evidence to conclusions)
Clifford v. Apfel, 227 F.3d 863 (7th Cir.) (ALJ must build an accurate and logical bridge from evidence to conclusion)
Hines v. Barnhart, 453 F.3d 559 (4th Cir.) (objective evidence is one factor in credibility analysis)