Billie J. Woods v. Nancy Berryhill
888 F.3d 686
| 4th Cir. | 2018Background
- Woods, a former production worker, stopped working in April 2013 due to inflammatory arthritis/osteoarthritis/fibromyalgia and applied for Social Security disability insurance benefits.
- NCDHHS (state Medicaid) issued a prior decision finding Woods disabled and eligible for Medicaid; the state hearing officer found her testimony credible and noted supportive lab/physical findings.
- Treating physicians (Drs. Aasheim and de Wit) limited Woods’ ability to perform heavy labor and, later, indicated substantial restrictions (e.g., occasional lifting up to 10 lbs; very limited standing/sitting; no climbing/stooping/kneeling).
- Consultative examiners (Drs. Burgess and Pardoll) and Woods’ testimony reported functional limits and pain; a nonexamining state consultant (Dr. Clayton) concluded Woods could perform medium work (e.g., lift 50 lbs, sit/stand 6 hours).
- The ALJ gave great weight to Dr. Clayton, little weight to treating physicians and the NCDHHS decision, found Woods’ symptom testimony not entirely credible, concluded Woods had RFC for medium work, and denied benefits.
- The Fourth Circuit vacated and remanded because the ALJ failed to provide adequate, specific reasons for discounting the NCDHHS disability determination and made other deficiencies in the RFC, credibility, and opinion-weighting analyses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight due to state agency (NCDHHS) disability decision | ALJ improperly gave the NCDHHS decision little weight; it is entitled to substantial consideration | NCDHHS decision not binding and ALJ reasonably discounted it; ALJ considered the record | Court: ALJ must generally give substantial weight to such state disability findings; if giving less, must supply persuasive, specific, valid, record-supported reasons. ALJ did not do so; remand required |
| Adequacy of RFC analysis | RFC not supported by an "accurate and logical bridge" from evidence to conclusion (medium work inconsistent with record) | ALJ summarized evidence and permissibly credited certain opinions supporting medium RFC | Court: ALJ failed to explain how credited evidence supports specific medium-work exertional limits; must fix on remand |
| Credibility assessment based on daily activities | ALJ overstated importance of Woods’ activities without assessing extent/limitations in performing them | ALJ relied on daily activities as inconsistent with claimed limitations | Court: ALJ must consider not only what activities claimant can do but the extent and effort required; current analysis deficient; remand to reassess credibility properly |
| Weight to medical opinions (nonexamining vs treating) | ALJ erred by favoring nonexamining Dr. Clayton over treating/examining physicians without adequate justification | Dr. Clayton’s opinion was consistent with record and thus properly relied upon | Court: Generally give more weight to treating/examining sources; nonexamining opinions require strong supportability/consistency to justify great weight. Here the ALJ’s reasons were insufficient; must reconsider on remand |
Key Cases Cited
- Mascio v. Colvin, 780 F.3d 632 (4th Cir.) (describing RFC narrative requirement and five-step evaluation framework)
- Bird v. Commissioner of Social Security Administration, 699 F.3d 337 (4th Cir.) (agency must give substantial weight to related agency disability ratings absent good reason)
- DeLoatche v. Heckler, 715 F.2d 148 (4th Cir.) (prior agency determinations should be considered)
- McCartey v. Massanari, 298 F.3d 1072 (9th Cir.) (ALJ must give specific, persuasive reasons to discount other-agency determinations)
- Chambliss v. Massanari, 269 F.3d 520 (5th Cir.) (ALJ need not defer to VA if valid reasons are provided)
- Radford v. Colvin, 734 F.3d 288 (4th Cir.) (ALJ must build an "accurate and logical bridge" from evidence to conclusions)
- Monroe v. Colvin, 826 F.3d 176 (4th Cir.) (requiring narrative discussion when weighing medical opinions)
- Brown v. Commissioner, 873 F.3d 251 (4th Cir.) (ALJ must consider extent of daily activities when assessing credibility)