Davis v. Commissioner of Social Security Administration, 8:15-cv-02991

Roger D. Davis, Jr. applied for Disability Insurance Benefits (DIB) and SSI on July 19, 2012, alleging disability beginning May 20, 2012; SSA denied benefits and an ALJ issued an unfavorable decision on January 31, 2014.
ALJ found one severe impairment: lumbar degenerative disc disease; non-severe: left thumb amputation, hypertension, obesity.
ALJ assessed an RFC for sedentary work with sit/stand option at will and no exposure to additional hazards, and found Davis could not perform his past relevant work but could perform other jobs existing in significant numbers.
Davis appealed to the Appeals Council (denied) and filed suit in district court; Magistrate Judge Austin recommended affirmance; Davis objected to the R&R arguing lack of substantial evidence and misapplication of the treating-physician rule regarding Dr. John Glaser.
District Court conducted de novo review of objections, found the ALJ’s credibility and RFC analysis supported by substantial evidence (noting post-operative improvement and activities of daily living), and held the ALJ properly weighed Dr. Glaser’s opinions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ’s decision is supported by substantial evidence	Davis: Record of ongoing pain and objective findings preclude affirmance; ALJ failed to address material evidence	Commissioner: ALJ considered full record, credited post-surgery improvement and daily activities; need not cite every piece of evidence	Affirmed — ALJ’s credibility, RFC analysis supported by substantial evidence
Whether ALJ properly applied Treating Physician Rule to Dr. Glaser’s opinions	Davis: ALJ failed to properly weigh or give controlling weight to treating surgeon’s disability statements	Commissioner: Dr. Glaser’s opinions were contemporaneous, limited to prior work, and unsupported by clinical findings; ALJ permissibly discounted unsupported opinion	Affirmed — ALJ adequately explained reasons for discounting treating physician opinion

Thomas v. Arn, 474 U.S. 140 (procedural rule on de novo review of magistrate judge recommendations)
Mathews v. Weber, 423 U.S. 261 (district court retains responsibility for final determination on magistrate recommendations)
Hays v. Sullivan, 907 F.2d 1453 (standard: review limited to substantial evidence and correct law)
Johnson v. Barnhart, 434 F.3d 650 (substantial-evidence standard articulated)
Mastro v. Apfel, 270 F.3d 171 (same substantial-evidence framework)
Craig v. Chater, 76 F.3d 585 (two-step pain/symptom evaluation and factors for assessing credibility)
Coffman v. Bowen, 829 F.2d 514 (ALJ findings not binding if based on improper legal standard)