Davis v. Colvin, 5:16-cv-00657

Plaintiff Berthea Victoria Davis (b. 1962) applied for SSI on December 18, 2013, alleging disability from HIV, degenerative disc disease, lupus, anxiety, and substance abuse; ALJ denied benefits and Appeals Council denied review.
ALJ found severe impairments of lumbosacral degenerative disc disease and polysubstance abuse; found cervical disorder, HIV, discoid lupus, anxiety non-severe; RFC: unskilled light work; no disability.
Objective imaging: 2010 cervical and lumbar MRIs showing multilevel disc disease; 2014 cervical MRI reporting multilevel spinal and foraminal stenosis with cord flattening at C3–C6.
Multiple treating providers (Drs. Howard and Awayda) opined significant functional limits (many activities "very limited" or "moderately limited"); consultative examiner Dr. Ganesh found only mild or no gross limitations and the ALJ gave that opinion great weight.
Plaintiff argued the ALJ mischaracterized the 2014 cervical MRI (calling it "minimal"), improperly substituted a lay interpretation for medical opinions, and therefore erroneously discounted treating-source opinions and reached an unsupported RFC.
District Court granted the plaintiff’s motion, concluding the ALJ impermissibly interpreted MRIs, misweighed medical opinions based on that lay interpretation, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ impermissibly interpreted objective MRI findings (cervical and lumbar) at step two	ALDavis: ALJ mischaracterized the 2014 cervical MRI as "minimal," substituting lay interpretation for medical readings and thus misstating severity	Commissioner: ALJ reasonably weighed imaging and other record evidence in finding cervical impairment non-severe	Held: ALJ erred by relying on her own lay interpretation of the MRIs; this mischaracterization infected later weighing of opinions and RFC determination
Whether the ALJ gave proper weight to treating physicians' opinions	Davis: Treating opinions were discounted based on the ALJ's erroneous step-two finding and on an improper focus on lumbar treatment paucity; ALJ failed to give good reasons	Comm'r: Substantial evidence supports giving limited weight to treating opinions and great weight to consultative examiner	Held: ALJ failed to give adequate reasons for discounting treating opinions because she based rejection on her erroneous MRI interpretation and treated/non-severe distinction; remand required
Whether RFC is supported by substantial evidence	Davis: RFC rests on flawed evidentiary weighing and lay interpretation of imaging and consultative report	Comm'r: RFC is supported by substantial evidence, including consultative examiner and objective record	Held: RFC not supported because it relied on the ALJ's improper interpretations and misweighing of medical opinions; remand necessary

Richardson v. Perales, 402 U.S. 389 (administrative findings supported by "substantial evidence")
Wagner v. Secretary of Health & Human Servs., 906 F.2d 856 (2d Cir. 1990) (district court may not substitute de novo determination for Commissioner)
Rutherford v. Schweiker, 685 F.2d 60 (ALJ findings must be upheld when supported by substantial evidence and reasonable inferences)
Halloran v. Barnhart, 362 F.3d 28 (2d Cir. 2004) (remand where ALJ fails to give good reasons for weight assigned to treating physician)
Greek v. Colvin, 802 F.3d 370 (consultative and treating opinions weighed under regulations)
Valente v. Secretary of Health & Human Servs., 733 F.2d 1037 (court may not substitute its judgment for ALJ where substantial evidence supports decision)
McIntyre v. Colvin, 758 F.3d 146 (sequential five-step process and standards for evaluating disability)