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Derrick Thaxton v. Comm'r of Soc. Sec.
19-6295
| 6th Cir. | Jun 9, 2020
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Background

  • Derrick Thaxton, a former towboat captain, filed for SSDI and SSI alleging bipolar disorder, anxiety, PTSD, agoraphobia, and alcohol dependence after being found medically unfit by the Coast Guard in 2013.
  • Treatment records (2013–2017) show chronic mental-health conditions treated at Owensboro Psychiatry, with periods of severe symptoms (panic attacks, agoraphobia, rapid-cycling mood) but also repeated normal/appropriate mental-status findings and documented improvement on medication.
  • Treating psychiatrist Snehamala Veeravalli, M.D., and therapist Mary Edwards produced opinions describing severe, work-preclusive limitations (including near impossibility of public interaction and likely three missed workdays/month).
  • Consultative examiner Marcy Walpert found Thaxton anxious and depressed and opined he likely could not tolerate day-to-day work; state agency reviewers rated most work-related limitations as no greater than moderate.
  • After initial administrative and district-court proceedings (including an earlier remand for inadequate articulation of reasons), an ALJ on remand assigned little weight to Dr. Veeravalli’s and Walpert’s opinions, gave great weight to state consultants, found Thaxton able to perform sustained full-time work, and the Sixth Circuit affirmed, treating any procedural error as harmless.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the ALJ gave “good reasons” for not giving controlling weight to the treating psychiatrist’s opinion Thaxton: ALJ failed to state controlling-weight analysis under 20 C.F.R. § 404.1527(c) and did not adequately balance the §404.1527 factors or provide specific reasons Commissioner: ALJ thoroughly reviewed the record, identified inconsistencies between the treating opinion and the clinician’s own notes and other evidence, and furnished specific, evidence-based reasons; any technical omission was harmless Court: Although the ALJ did not use the term “controlling weight” or explicitly recite each §404.1527 factor, the ALJ provided specific, detailed reasons showing inconsistency with the record; any procedural defect was harmless
Whether the ALJ impermissibly cherry-picked evidence and whether substantial evidence supports the RFC Thaxton: ALJ highlighted isolated improving entries and ignored pervasive severe limitations, so RFC unsupported Commissioner: ALJ considered the whole record (including claimant’s own statements of improvement), identified specific discrepancies, and relied on state consultants; reasonable minds could accept the RFC Court: The ALJ’s evaluation was supported by substantial evidence; the record supports the ALJ’s resolution of conflicts and the RFC determination

Key Cases Cited

  • Cardew v. Comm’r of Soc. Sec., 896 F.3d 742 (6th Cir. 2018) (standard of review and deference to ALJ when supported by substantial evidence)
  • Biestek v. Comm’r of Soc. Sec., 880 F.3d 778 (6th Cir. 2017) (definition of substantial evidence standard as applied in social-security cases)
  • Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (substantial evidence standard explained)
  • Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (procedural requirements for weighing medical opinions and when remand is required)
  • Gayheart v. Comm’r of Soc. Sec., 710 F.3d 365 (6th Cir. 2013) (treating-physician rule and factors for weighing a treating source’s opinion)
  • Gentry v. Comm’r of Soc. Sec., 741 F.3d 708 (6th Cir. 2014) (treating-source opinion entitled to deference even when not controlling)
  • Cole v. Astrue, 661 F.3d 931 (6th Cir. 2011) (failure to assign any weight to treating opinion can require remand)
  • Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (the "good reasons" rule for explaining weight given to treating-source opinions)
  • Nelson v. Comm’r of Soc. Sec., 195 F. App’x 462 (6th Cir. 2006) (ALJ may meet the goal of §404.1527 by implicitly providing sufficient reasons in the record)
  • Karger v. Comm’r of Soc. Sec., 414 F. App’x 739 (6th Cir. 2011) (discussing adequacy of an ALJ’s explanation and need to identify specific discrepancies)
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Case Details

Case Name: Derrick Thaxton v. Comm'r of Soc. Sec.
Court Name: Court of Appeals for the Sixth Circuit
Date Published: Jun 9, 2020
Docket Number: 19-6295
Court Abbreviation: 6th Cir.