Anderson v. Commissioner of Social Security Administration, 9:14-cv-00832

Background

Plaintiff Rita Williams Anderson (born 1962) applied for Disability Insurance Benefits (DIB) alleging disability beginning May 1, 2010, due to multiple physical and mental conditions.
Initial and reconsideration denials were issued in 2011; ALJ held a hearing in June 2012 and found Plaintiff capable of the full range of sedentary work.
The Appeals Council granted review but ultimately affirmed that Plaintiff was not disabled from May 1, 2010 through June 30, 2011; that decision became the Commissioner’s final decision.
Plaintiff filed suit seeking judicial review under 42 U.S.C. §§ 405(g) and 1383(c)(3). The Magistrate Judge recommended affirmance; Plaintiff filed objections.
Central contested issues: ALJ’s RFC finding for sedentary work, assessment of Plaintiff’s subjective complaints and daily activities, and the weight given to treating physician Dr. Brian N. Anderson’s opinion (including a June 2012 statement that Plaintiff was “totally disabled”).
District court adopted the Magistrate Judge’s Report, found no clear error, concluded substantial evidence supported the Commissioner’s decision, and affirmed denial of DIB.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ’s RFC finding (full range of sedentary work) is supported by substantial evidence	Anderson contends the ALJ overstated functioning and selectively relied on records	Commissioner argues ALJ considered testimony, medical record, and activities and reasonably concluded sedentary RFC	Court held substantial evidence supports ALJ’s sedentary RFC finding; affirmed
Whether ALJ properly discounted treating physician’s opinion that Plaintiff is ‘‘totally disabled’’	Anderson argues no persuasive contradictory evidence rebuts Dr. Anderson’s opinion	Commissioner notes disability determination is reserved to SSA and ALJ reasonably discounted it as inconsistent with records and claimant’s reports	Court held ALJ properly gave less than controlling weight to that opinion; affirmed
Whether the ALJ properly evaluated Plaintiff’s credibility and activities of daily living	Anderson argues the ALJ improperly discounted subjective complaints	Commissioner points to inconsistencies between reported activities/examination findings and claimed limitations	Court found ALJ’s credibility assessment supported by record and not reversible error
Whether procedural review by Magistrate Judge and District Court complied with standards for objections	Anderson lodged general objections rehashing prior arguments	Commissioner asked court to adopt Magistrate’s Report	Court found objections not specific enough to require de novo review, found no clear error, and accepted Report

Key Cases Cited

Diamond v. Colonial Life & Acc. Ins. Co., 416 F.3d 310 (4th Cir. 2005) (standard for district court review of magistrate judge’s report and recommendations)
Camby v. Davis, 718 F.2d 198 (4th Cir. 1983) (failure to file specific objections waives further review)
Orpiano v. Johnson, 687 F.2d 44 (4th Cir. 1982) (magistrate report review standards)
Thomas v. Celebrezze, 331 F.2d 541 (4th Cir. 1964) (definition of substantial evidence)
Vitek v. Finch, 438 F.2d 1157 (4th Cir. 1971) (courts must give careful scrutiny to administrative record)
Blalock v. Richardson, 483 F.2d 773 (4th Cir. 1972) (upholding Commissioner where supported by substantial evidence)
Flack v. Cohen, 413 F.2d 278 (4th Cir. 1969) (courts should not uncritically accept agency findings)
Castellano v. Sec’y of Health & Human Servs., 26 F.3d 1027 (10th Cir. 1994) (physician’s statement that claimant is disabled is not dispositive)