Brown v. Astrue
649 F.3d 193
| 3rd Cir. | 2011Background
- Brown, a 51-year-old with a history of violent crime and drug abuse, applied for SSI in March 2006 alleging disability since April 2002 due to bipolar disorder and anxiety.
- Initial SSI denial occurred in October 2006 for not being severe enough to prevent work.
- An ALJ held a February 2008 hearing and found Brown not disabled, concluding he could adjust to other work existing in significant numbers.
- Brown sought review; the Appeals Council denied review, and Brown sued in district court in May 2009.
- The magistrate appropriately recommended denial; the district court adopted that recommendation, affirming substantial evidence supporting the ALJ.
- Brown appeals to the Third Circuit challenging the magistrate’s handling and the ALJ’s weighing of medical evidence, credibility, and functional capacity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review on magistrate findings | Brown argues de novo review applies to magistrate findings in SSI. | Brown's objections should be reviewed de novo only on timely, specific objections; Morgan guidance was misapplied. | Error harmless; substantial evidence supported ALJ findings. |
| Weight given to treating psychiatrist | Brown contends ALJ erred by not adopting treating psychiatrist's opinion. | ALJ properly weighed treating vs non-treating medical opinions and credited Cohen's assessment of simple tasks. | ALJ's weighing of opinions was supported by substantial evidence. |
| Credibility and functional capacity | Brown argues his claimed limitations were not properly credible or reflected in his residual functional capacity. | ALJ credited record evidence of functioning and Cohen's assessment that Brown could perform simple, routine work. | ALJ's credibility and functional capacity determinations were supported by substantial evidence. |
Key Cases Cited
- Knepp v. Apfel, 204 F.3d 78 (3d Cir.2000) (substantial evidence standard for SSI review)
- Goney v. Clark, 749 F.2d 5 (3d Cir.1984) (de novo review of objections in SSI context)
- Renchenski v. Williams, 622 F.3d 315 (3d Cir.2010) (harmless error when no set of facts to grant relief)
- Hartranft v. Apfel, 181 F.3d 358 (3d Cir.1999) (court binds to substantial evidence; can affirm despite different conclusions)
- Morales v. Apfel, 225 F.3d 310 (3d Cir.2000) (treating vs non-treating physician opinions; ALJ may credit non-treating evidence)
- Adorno v. Shalala, 40 F.3d 43 (3d Cir.1994) (treating physician's opinion is not dispositive of functional capacity)
- Plummer v. Apfel, 186 F.3d 422 (3d Cir.1999) (substantial evidence standard for evaluating functional capacity)
- Jones v. Sullivan, 954 F.2d 125 (3d Cir.1991) (ALJ may disregard treating physician if state agency findings do not show preclusion from work)