Camille v. Colvin
104 F. Supp. 3d 329
W.D.N.Y.2015Background
- Plaintiff Brian M. Camille (then ~24) applied for Social Security disability benefits alleging bipolar disorder, depression, anxiety, ADHD, syncope/seizures and related limitations; alleged onset November 1, 2009.
- Treating psychiatrist Muhammad Dawood, M.D., consistently treated Plaintiff, assigned GAF scores ~55, and completed two mental RFC questionnaires concluding Plaintiff could not sustain competitive employment and would miss >4 workdays/month.
- State agency reviewer E. Kamin (non‑examining) assessed moderate limitations but concluded Plaintiff could do low‑stress work with sustained attention for simple tasks; a consultative internal medicine exam found no limiting physical deficits.
- ALJ Susan Wakshul held a hearing (vocational expert testimony), assigned an RFC for medium work with marked nonexertional limits (simple, routine, repetitive tasks; limited social interaction; no public contact; limited exposure to hazards and humidity/extremes), and found jobs available (laundry worker, hand packager, mail clerk).
- Appeals Council denied review; District Court reviewed the Commissioner’s final decision and affirmed, holding the ALJ’s findings supported by substantial evidence and consistent with law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight accorded to treating psychiatrist opinion (Dr. Dawood) | ALJ failed to apply treating‑physician rule and §404.1527(c) factors; gave insufficient reasons for discounting Dr. Dawood’s RFCs | ALJ permissibly gave Dr. Dawood little weight because his opinion conflicted with his own treatment notes and other record evidence; ALJ incorporated many limitations | Court held ALJ gave "good reasons"; Dr. Dawood’s checklist form opinions were inconsistent with treatment notes/GAFs and with other evidence, so little weight was permissible |
| Reliance on non‑examining state consultant (Dr. Kamin) | Dr. Kamin’s opinion was stale and based on an incomplete record (pre‑dated later treating opinions and summaries) | Dr. Kamin’s opinion was consistent with the medical record and thus entitled to weight; ALJ also added accommodations beyond that opinion | Court held ALJ permissibly gave great weight to Dr. Kamin because his opinion aligned with records both before and after his review; any later evidence did not materially change the picture |
| Credibility assessment of Plaintiff’s subjective complaints | ALJ used boilerplate and improperly based credibility on RFC; failed to consider medication changes, memory/fatigue adequately | ALJ applied the two‑step credibility test, considered daily activities, treatment history, medications, and objective findings; RFC limited concentration/memory | Court held ALJ’s credibility determination was supported by substantial evidence despite some boilerplate language; ALJ considered required factors and addressed concentration/memory in RFC |
| Step‑5 vocational determination (reliance on VE) | RFC and credibility errors taint the VE hypothetical and step‑5 finding | VE testimony reasonably tracked ALJ’s RFC; substantial evidence supports that jobs exist Plaintiff can perform | Court held reliance on VE was proper because RFC was supported by substantial evidence and VE testimony identified jobs in significant numbers |
Key Cases Cited
- Consol. Edison Co. v. NLRB, 305 U.S. 197 (U.S. 1938) (defines substantial evidence standard)
- Johnson v. Bowen, 817 F.2d 983 (2d Cir. 1987) (error in applying correct legal principles warrants remand)
- Mongeur v. Heckler, 722 F.2d 1033 (2d Cir. 1983) (scope of district court review of ALJ decision)
- Halloran v. Barnhart, 362 F.3d 28 (2d Cir. 2004) (treating physician rule and factors for weighing treating opinions)
- Zabala v. Astrue, 595 F.3d 402 (2d Cir. 2010) (harmless‑error approach where additional evidence would not change outcome)
- Cichocki v. Astrue, 729 F.3d 172 (2d Cir. 2013) (no requirement that ALJ address every work‑related function explicitly when proper standards applied)