Charles Gayheart v. Commissioner of Social Security
2013 U.S. App. LEXIS 4865
| 6th Cir. | 2013Background
- Gayheart applied for Social Security DIB in Dec. 2005 due to anxiety, panic disorder, bipolar disorder, and depression.
- ALJ denied DIB after three hearings; district court initially upheld denial and final decision.
- Magistrate recommended remand for award of benefits, district court sustained Commissioner’s objections, appellate review followed.
- Record shows extensive treatment by therapy and psychiatry with diagnoses including panic disorder, generalized anxiety, bipolar II, and alcohol use issues.
- Consultative and treating opinions were in tension; ALJ discounted treating sources while relying on some consultative opinions.
- This Court reverses and remands for reconsideration, including weighing treating opinions and alcohol-abuse materiality issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| weighing of medical opinions | Gayheart structural claim: treating opinions should be given controlling weight | ALJ properly weighed opinions per 404.1527(c) and regula tions | Remand for proper weighing of treating opinions |
| controlling weight for treating sources | Onady’s opinions deserve controlling weight | Onady’s opinions not controlling if not well-supported | ALJ failed to provide good reasons; remand warranted |
| materiality of alcohol abuse | Alcoholism may be a contributing factor needing proper evaluation | Alcohol abuse not considered until disability is found; materiality not resolved | Need reanalysis on remand regarding alcohol-materiality |
| whether substantial evidence supports denial at steps 3-5 | Record could meet/listing 12.06 with proper weight | Record supports ALJ given weight and RFC | Remand to reassess under proper standards |
Key Cases Cited
- Cole v. Astrue, 661 F.3d 931 (6th Cir. 2011) (remand when treating-physician rule not properly applied)
- Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (requirement to provide good reasons for discounting treating opinions)
- Heston v. Comm’r of Soc. Sec., 245 F.3d 528 (6th Cir. 2001) (substantial evidence standard and deferential review)
- Colvin v. Barnhart, 475 F.3d 727 (6th Cir. 2007) (defining substantial-evidence standard and review limits)
- White v. Comm’r of Soc. Sec., 572 F.3d 272 (6th Cir. 2009) (GAF and functional impairment discussion in Social Security context)