Betty Thompson v. Michael Astrue
442 F. App'x 804
4th Cir.2011Background
- Thompson appeals district court's affirmation of denial of DIB and SSI under 42 U.S.C. §§ 405(g).
- ALJ found Thompson could perform past relevant work and considered her mental impairments; credibility and sit-stand issue discussed.
- Court reviews for substantial evidence and correct legal standard in a five-step disability framework.
- Thompson's severe impairments included depression and generalized anxiety; ALJ found they did not restrict basic work activity and mental RFC not limited.
- ALJ gave less weight to treating physician Dr. Hughes' opinion; other physicians and state consultants found Thompson could perform light/sedentary work; credibility assessed under Craig framework.
- Court affirms district court, concluding substantial evidence supports the agency's decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Step four finding on past relevant work | Thompson contends ALJ erred by finding past work feasible given mental impairments and sit-stand needs. | Thompson's RFC and hypothetical reflect all evidence; no error in comparing to telemarketer demands. | No reversible error; substantial evidence supports ability to perform past work. |
| Weight afforded to treating physician Dr. Hughes | Dr. Hughes' opinion should receive controlling weight as treating physician. | Dr. Hughes provided no functional explanation; others found no significant impairments; treating-physician rule not controlling here. | ALJ properly afforded less weight to Dr. Hughes' conclusory opinion. |
| Credibility analysis of Thompson's pain/credible statements | ALJ failed to adequately explain why she found Thompson not credible at hearing. | ALJ's credibility assessment supported by objective evidence, treatment history, and observations per SSR 96-7p. | Credibility determination supported by substantial evidence. |
Key Cases Cited
- Bowen v. Yuckert, 482 U.S. 137 (Supreme Court 1987) (established five-step framework for disability analysis)
- Johnson v. Barnhart, 434 F.3d 650 (4th Cir. 2005) (substantial evidence standard; defer to Commissioner when reasonable minds differ)
- English v. Shalala, 10 F.3d 1080 (4th Cir. 1993) (emphasizes substantial evidence standard and hypothetical ORM requirements)
- Craig v. Chater, 76 F.3d 585 (4th Cir. 1996) (treating physician rule; limitations on weight of treating opinions)
- Mastro v. Apfel, 270 F.3d 171 (4th Cir. 2001) (disability opinions; justification required for weight given to treating source)