Brian Reid v. Commissioner of Social Security
769 F.3d 861
4th Cir.2014Background
- Reid applied for Title II disability benefits on December 7, 2006, alleging disability began June 4, 2004 after a fall from a roof.
- Prior to the fall, Reid had cervical disc disease treated with a two-level discectomy and fusion in December 2003.
- Following the June 2004 fall, Reid had thoracic/lumbar fractures and underwent a posterior fusion in February 2005, with noted progress thereafter.
- In 2006 Reid developed leg pain with vascular issues, undergoing iliac artery angioplasty on May 30, 2006, and later reported continued improvement.
- ALJ denied benefits in 2009; Appeals Council remanded to consider evidence from 2004 forward and Reid’s mental impairments and obesity; a second hearing in 2011 again denied benefits; the Appeals Council’s decision became final.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the record fully considered? | Reid contends the ALJ failed to consider 2004–2006 evidence. | Commissioner argues the record was considered and referenced appropriately. | Yes; substantial evidence supports that the record was considered. |
| Did the ALJ properly evaluate the combined impairments? | Reid argues the impairments were not evaluated in combination. | ALJ and Appeals Council adequately considered cumulative effects. | Yes; combination of impairments adequately considered. |
Key Cases Cited
- Hackett v. Barnhart, 395 F.3d 1168 (10th Cir. 2005) (consideration of matter declared by lower tribunal)
- Walker v. Bowen, 889 F.2d 47 (4th Cir. 1989) (requirement to explain combined impairments)
- Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (no rigid point-by-point discussion rule)
- Johnson v. Barnhart, 434 F.3d 650 (4th Cir. 2005) (substantial evidence standard for review)