Chapo v. Astrue
682 F.3d 1285
| 10th Cir. | 2012Background
- Chapo appeals a district court order upholding the Commissioner’s denial of disability and SSI benefits; the court independently reviews for legal error and substantial evidence.
- The ALJ denied benefits at the fifth step, finding light work with postural limits and restricted public contact, and relying on VE testimony to conclude available jobs.
- The ALJ accorded great weight to Dr. Amin (2008) for physical RFC and gave little weight to Dr. Krause (2009) and to Dr. Vega (mental RFC) as well as to LCSW Clemens.
- Dr. Vega provided a detailed mental RFC indicating severe limitations across multiple functional domains.
- The ALJ discounted Dr. Vega’s findings largely on the basis of a short treating relationship, which the court finds invalid as a sole basis to reject uncontradicted opinions; the VE’s hypothetical did not adequately reflect Vega’s restrictions.
- The court reverses and remands for new proceedings, including potential updated mental RFC or a proper hypothetical to the VE consistent with Vega’s findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the RFC properly reflects medical opinions. | Chapo argues the RFC does not match the medical opinions. | Chapo contends the ALJ can reconcile opinions to form RFC. | Remanded for proper RFC determination and consideration of Vega. |
| Whether the ALJ properly handled Dr. Vega’s mental RFC findings. | ALJ erred by discounting Vega’s full mental RFC and relying on short treating relationship. | ALJ can discount or treat Vega as examining source; other factors apply. | Remand required to address Vega’s uncontradicted findings and VE reliance. |
Key Cases Cited
- Howard v. Barnhart, 379 F.3d 945 (10th Cir. 2004) (RFC determinations may be made by the ALJ from the record)
- Wall v. Astrue, 561 F.3d 1048 (10th Cir. 2009) (five-step disability analysis)
- Krauser v. Astrue, 638 F.3d 1324 (10th Cir. 2011) (independent review for legal error and substantial evidence)
- Doyal v. Barnhart, 331 F.3d 758 (10th Cir. 2003) (must provide legitimate reasons for rejecting examining evidence)
- Winfrey v. Chater, 92 F.3d 1017 (10th Cir. 1996) (examining opinion presumptively entitled to weight)
- Bernal v. Bowen, 851 F.2d 297 (10th Cir. 1988) (mental RFC findings may be made without treating/opinion support)
- Barnett v. Apfel, 231 F.3d 687 (10th Cir. 2000) (hypothetical to VE must include all limitations found)
- Andrade v. Secretary of Health & Human Services, 985 F.2d 1045 (10th Cir. 1993) (regarding need for medical opinion in mental RFC)