Cooper v. Social Security Administration
4:12-cv-00561
N.D. Okla.Jan 21, 2014Background
- Plaintiff Linda Cooper filed for Title II and XVI disability benefits, alleging onset October 3, 2007, and insured through March 31, 2011.
- ALJ determined she had a severe impairment of degenerative disc disease post-surgery and applied a mental impairment analysis under a special technique.
- ALJ found mild mental impairments, did not meet Listing 1.04, and assessed an RFC of light work with certain postural limits.
- Medical record evidence included pre- and post-surgical back pain, discography results, MRI findings, and consultative examinations.
- Treating sources and a third-party function report were given limited weight, while State agency opinions were given substantial weight; the Appeals Council denied review.
- Plaintiff challenged the ALJ’s credibility analysis and other aspects, and the district court remanded for a proper credibility linkage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility analysis linkage to findings | Cooper argues the ALJ inadequately linked facts to credibility. | Colvin contends the ALJ properly evaluated credibility under SSR 96-7p. | Remanded for proper, explicit credibility linkage. |
| Treating source opinions and mental impairment analysis | Plaintiff asserts treating-source opinions and Listing 1.04(a) were improperly handled. | Defendant argues substantial weight given to other medical opinions; no error in Listing analysis. | No decisive holding; remand on credibility affects these aspects. |
| RFC and sit/stand postural option | RFC did not incorporate alternate sit/stand option as reflected in evidence. | RFC supported by record; not error. | Remand to allow proper credibility-evidentiary linkage may affect RFC. |
| Consideration of Dorothy Cooper’s third-party report | Report ignored or given insufficient weight. | Court found report to be brief and cumulative with limited added value. | No explicit error; remand ordered to reassess credibility with proper link to evidence. |
Key Cases Cited
- White v. Barnhart, 287 F.3d 903 (10th Cir. 2002) (standard for credibility review; deferential but linked to substantial evidence)
- Grogan v. Barnhart, 399 F.3d 1257 (10th Cir. 2005) (court may not reweigh evidence; substantial evidence standard)
- Hackett v. Barnhart, 395 F.3d 1168 (10th Cir. 2005) (substantial evidence and consistency in ALJ findings)
- Qualls v. Apfel, 206 F.3d 1368 (10th Cir. 2000) (no formalistic factor-by-factor recitation required; credibility factors vary)
- Kepler v. Chater, 68 F.3d 387 (10th Cir. 1995) (credibility factors and evaluation guidance (SSR 96-7p context))