2:20-cv-00246
E.D. Tex.Jul 18, 2022Background:
- ALJ Evangeline Mariano-Jackson (Feb 26, 2020) found Davis (b. 1961; HS + some college) not disabled from May 15, 2017 through the decision date; severe impairments: COPD, major depressive disorder, anxiety, ADD, PTSD.
- ALJ determined Davis had RFC for the full range of work at all exertional levels but with nonexertional limits (frequent climbing; only occasional exposure to pulmonary irritants, extreme temperatures, direct sunlight; detailed but not complex tasks; no fast-paced production; limited coworker/supervisor/public contact).
- ALJ relied on a vocational expert who identified medium/heavy jobs (warehouse worker, building maintenance laborer, hand packager); ALJ concluded Davis could perform jobs existing in significant numbers and denied benefits; Appeals Council denied review.
- Davis challenged the RFC: (1) ALJ failed to properly address consultative examiner Dr. D. Daniel’s exertional lifting/carrying limits (which, if credited, would preclude medium/heavy work); (2) ALJ improperly discounted treating psychiatrist Dr. Paul Young’s extreme mental restrictions; and (3) ALJ failed to give adequate weight to Davis’s strong work history in assessing credibility.
- District court found the ALJ erred by failing to address Dr. Daniel’s lifting/carrying limitations (critical because the VE jobs were medium/heavy), leaving the RFC unsupported by substantial evidence; the court upheld the ALJ’s handling of the psychiatric opinions/credibility. Case reversed and remanded under sentence four for further proceedings.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ’s RFC is supported by substantial evidence given Dr. Daniel’s physical exertional limits | Davis: ALJ ignored Dr. Daniel’s lift/carry limits which would eliminate identified medium/heavy work | Comm’r: ALJ permissibly weighed medical evidence, relied on other findings and permissibly rejected inconsistent portions | Court: ALJ failed to address lift/carry limits; RFC that claimant can perform all exertional levels not supported — remand required |
| Whether ALJ properly weighed psychiatric opinions and credibility (including work history) | Davis: ALJ discounted Davis’s testimony and ignored stellar work history | Comm’r: ALJ’s credibility finding is supported by record and she discussed treating psychiatrist’s extreme opinions | Court: ALJ adequately explained rejecting Dr. Young’s extreme limitations and credibility assessment is supported; no reversible error on credibility |
Key Cases Cited
- Martinez v. Chater, 64 F.3d 172 (5th Cir. 1995) (district-court review limited to substantial evidence and correct legal standards)
- Ripley v. Chater, 67 F.3d 552 (5th Cir. 1995) (definition and application of substantial evidence)
- Scott v. Heckler, 770 F.2d 482 (5th Cir. 1985) (treating/medical-opinion deference and good-cause exceptions to give less weight)
- Moore v. Sullivan, 919 F.2d 901 (5th Cir. 1990) (ALJ has sole responsibility to determine disability)
- Abshire v. Bowen, 848 F.2d 638 (5th Cir. 1988) (no substantial evidence where conspicuous absence of credible choices or no contrary medical evidence)
- Singletary v. Bowen, 798 F.2d 818 (5th Cir. 1986) (court must consider the whole record and take into account evidence that detracts from its weight)