Crowell v. Commissioner of Social Security Administration
705 F. App'x 34
| 2d Cir. | 2017Background
- Plaintiff Nathaniel H. Crowell, pro se, sought Social Security disability insurance benefits; an ALJ denied benefits and the Commissioner’s final decision was upheld by the district court.
- Crowell’s primary impairment was chronic diarrhea dating back to hospitalization in 2002; he argued it met Listing 14.08I (diarrhea resistant to treatment requiring IV hydration/alimentation or tube feeding).
- The ALJ found Crowell did not meet Listing 14.08I, had medically improved in 2004, and retained the capacity for sedentary work.
- The ALJ discounted a treating physician’s opinion that Crowell met the listing, finding it inconsistent with the record.
- The district court granted judgment on the pleadings for the Commissioner; Crowell appealed to the Second Circuit.
- The Second Circuit reviewed de novo whether the ALJ applied correct legal standards and whether substantial evidence supported the decision, and affirmed the district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Crowell’s diarrhea met Listing 14.08I | Crowell asserted his chronic diarrhea was resistant to treatment and met the listing requiring IV/tube support | Commissioner argued Crowell’s condition did not meet the listing and records showed only episodic diarrhea after 2002 | Court held Crowell did not meet Listing 14.08I; substantial evidence supported ALJ’s finding |
| Whether the ALJ properly applied the treating physician rule | Crowell contended the ALJ failed to give controlling weight to his treating physician’s opinion that he met the listing | Commissioner maintained the ALJ permissibly discounted the treating opinion as inconsistent with the record and supported by reasons | Court held the ALJ substantively applied the treating physician rule and gave “good reasons” for discounting the opinion |
| Whether there was substantial evidence for the ALJ’s RFC and medical improvement findings | Crowell argued the record did not support the ALJ’s residual functional capacity and medical improvement conclusions | Commissioner pointed to medical records and testimony showing episodic symptoms and improvement consistent with sedentary work | Court held substantial evidence supported the ALJ’s RFC and medical improvement determinations |
| Whether the district court properly granted judgment on the pleadings | Crowell argued the agency decision should be reversed/remanded | Commissioner argued the administrative record and law supported affirmance | Court affirmed the district court’s judgment for the Commissioner |
Key Cases Cited
- Zabala v. Astrue, 595 F.3d 402 (2d Cir. 2010) (standard of review for district court judgment on the pleadings and review of Commissioner’s decision)
- Machadio v. Apfel, 276 F.3d 103 (2d Cir. 2002) (substantial evidence and legal standard review of agency determinations)
- Brault v. Soc. Sec. Admin. Comm'r, 683 F.3d 443 (2d Cir. 2012) (definition of substantial evidence and deference to ALJ factfindings)
- Sullivan v. Zebley, 493 U.S. 521 (1990) (claimant must meet all criteria of a listing to qualify)
- Burgess v. Astrue, 537 F.3d 117 (2d Cir. 2008) (treating physician rule and requirement to provide good reasons for weight given)
- Halloran v. Barnhart, 362 F.3d 28 (2d Cir. 2004) (ALJ must set forth reasons reflecting the §404.1527(d)(2) factors when assigning weight to treating opinions)