Braxton v. Colvin, 1:13-cv-02259

Background

Plaintiff William B. Braxton sought DIB and SSI, alleging disability from January 15, 2004; initial denials, ALJ denial in 2009, district court remand in 2011, and a second ALJ denial in 2012 became final.
ALJ found severe impairments: diabetes, hypertension, bilateral knee osteoarthritis, status post left knee arthroscopy, peripheral neuropathy, and hernias.
ALJ assessed an RFC for medium work with limitations: occasional left-leg push/pull, occasional climbing of ladders/ropes/scaffolds, and avoidance of concentrated exposure to extreme cold, vibration, and hazards.
ALJ gave little weight to an April 2012 treating-physician Physical RFC (Dr. Green) due to limited treatment history, medication-management notes, inconsistent objective support, and claimant noncompliance.
ALJ gave significant weight to a September 2008 treating note from Dr. Desai that plaintiff could work if sugars and blood pressure were better controlled; medical records showed diabetes often uncontrolled due to noncompliance.
Based on the RFC and vocational testimony/claimant statements about housekeeping duties, ALJ concluded Braxton could perform past relevant work as a housekeeper and was not disabled; the magistrate judge affirmed, denying plaintiff's summary judgment and granting the Commissioner’s.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight given to treating physician (Dr. Green) opinion	ALJ improperly rejected Dr. Green’s RFC and absenteeism/rest-period opinions	Dr. Green’s opinion was based on a brief treating relationship, contradicted by other records, and undermined by noncompliance notes	ALJ permissibly gave the opinion little weight; supported by substantial evidence
RFC and credibility findings	RFC omitted limiting effects of osteoarthritis and peripheral neuropathy and relied on adverse credibility findings	ALJ pointed to inconsistent symptom reports and generally normal exams; RFC incorporated limitations supported by record	ALJ’s RFC and credibility determinations supported by substantial evidence
Evaluation of subjective pain (two‑part Craig test)	ALJ failed to properly apply the two‑part pain analysis	ALJ identified objective impairments and analyzed intensity/persistence, citing inconsistencies with longitudinal record	ALJ complied with Craig analysis; no remand warranted
Step 4 past relevant work / VE conflict with DOT	ALJ failed to make specific findings about housekeeping demands and did not resolve an apparent DOT/VE conflict (work may be heavy)	ALJ relied on claimant’s hearing testimony about duties, VE present and classified the job as medium; single earlier report of heavier lifting was outweighed by hearing testimony	ALJ properly relied on claimant testimony and VE classification; no unresolved conflict and plaintiff could perform past work

Key Cases Cited

Craig v. Chater, 76 F.3d 585 (4th Cir. 1996) (two‑part pain/symptom evaluation and treating‑opinion standards discussion)
Webb v. Barnhart, 433 F.3d 683 (9th Cir. 2005) (discussion of step‑two "de minimis" severity screening)