Chandler v. Berryhill, 1:17-cv-01346

Background

Plaintiff (born 1965) applied for DIB with alleged onset March 1, 2014; ALJ denied benefits and Appeals Council denied review, making ALJ decision final.
Diagnosed with PTSD, major depressive disorder, and generalized anxiety disorder; treated with outpatient therapy and conservative medication management from 2014–2016.
Medical records show recurring panic attacks, insomnia, some neurocognitive complaints (possible adult-onset ADHD), but frequent mental-status notes describing normal orientation, intact memory, and improvement at times.
ALJ found plaintiff has severe mental impairments but no listing-level impairment; RFC: full range of exertional work but limited to simple, routine tasks; occasional changes; occasional public contact; off-task up to 10% of workday.
Vocational expert identified numerous unskilled jobs compatible with that RFC; ALJ concluded plaintiff not disabled. District Magistrate recommends affirming Commissioner.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
RFC fails to account for concentration/pace limits (Mascio)	ALJ did not explain how simple tasks capture moderate concentration deficits or plaintiff's productivity; RFC unsupported	ALJ incorporated nonexertional limits (simple tasks, occasional changes/public contact, 10% off-task) and explained the record; vocational expert hypothetical matched RFC	RFC supported: ALJ’s discussion addressed concentration/pace, consistent with Mascio when explained; RFC upheld
ALJ misstated credibility standard evaluating subjective symptoms	ALJ required to determine whether statements can "reasonably be accepted" and consider extent of inconsistencies; claims ALJ applied a heightened standard	ALJ followed two-step regulatory framework, considered objective evidence and activities, and built an "accurate and logical bridge" for credibility findings	Credibility determination supported by substantial evidence; no legal-error shown
ALJ erred in discounting plaintiff's allegations (specific factors)	ALJ ignored or misinterpreted medical notes, overstated stability, improperly relied on absence of aggressive treatment, and misapplied daily-activity evidence	ALJ reasonably weighed records showing largely intact cognitive/emotional exams, conservative outpatient care, periodic improvement, and daily activities consistent with RFC	ALJ’s weighing and explanations adequate; substantial evidence supports findings
Step 5 / SSR 85-15 vocational analysis inadequate	ALJ failed to analyze how nonexertional limits reduced occupational base and did not properly question VE per SSR 85-15; relied improperly on Grids (Bisceglia)	ALJ posed RFC-based hypothetical to VE, obtained jobs in national economy, and used Grids only as framework; VE testimony addressed nonexertional limits	VE testimony supplying representative jobs consistent with RFC satisfies SSR 85-15 here; step‑5 finding supported

Key Cases Cited

Mascio v. Colvin, 780 F.3d 632 (4th Cir. 2015) (restrictions to simple tasks do not automatically account for moderate limitations in concentration, persistence, or pace; ALJ must explain)
Mastro v. Apfel, 270 F.3d 171 (4th Cir. 2001) (standard of substantial evidence review)
Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (definition of substantial evidence)
Craig v. Chater, 76 F.3d 585 (4th Cir. 1996) (two-step framework for evaluating pain and credibility)
Monroe v. Colvin, 826 F.3d 176 (4th Cir. 2016) (ALJ must build an accurate and logical bridge from evidence to conclusions)
Woods v. Berryhill, 888 F.3d 686 (4th Cir. 2018) (ALJ must consider not just types of daily activities but extent to which claimant can perform them)
Winschel v. Comm’r, Soc. Sec. Admin., 631 F.3d 1176 (11th Cir. 2011) (courts recognize that simple, routine tasks do not necessarily capture deficits in concentration/pace)
Bisceglia v. Colvin, 173 F. Supp. 3d 326 (E.D. Va. 2016) (remand where ALJ failed to reconcile RFC with state-agency opinions and misapplied Grids)