Edward Ellars v. Comm'r of Social Security
647 F. App'x 563
6th Cir.2016Background
- Edward Ellars applied for Social Security disability insurance and SSI, alleging disability since 2008; he amended onset to June 1, 2012.
- ALJ found several "severe" impairments (CAD with stents, sleep apnea, prior carpal tunnel release, lupus, mild emphysema, depression) but determined they did not meet listings and concluded Ellars could perform a limited range of sedentary work.
- ALJ gave little weight to treating physician Dr. Gregory Schall’s Physical Capacity Evaluation, which checked severe limitations (extreme limits on sitting/standing/walking; frequent absences) without detailed explanation.
- Appeals Council denied review; district court adopted magistrate judge’s R&R affirming the ALJ, and Ellars appealed to the Sixth Circuit.
- Sixth Circuit reviewed whether the ALJ properly weighed the treating physician’s opinion and whether the ALJ provided "good reasons" supported by substantial evidence for discounting it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ failed to give proper deference to treating physician’s opinion | Ellars: ALJ erred by not giving Dr. Schall controlling or significant weight for severe functional limits | ALJ: Dr. Schall’s opinion was conclusory, unsupported by objective evidence, inconsistent with record; ALJ gave adequate reasons | Court affirmed: ALJ gave "good reasons" supported by record to discount the treating opinion |
| Whether ALJ required corroboration by another physician (new rule) | Ellars: ALJ improperly imposed a requirement that another physician must concur for weight | ALJ: Comment merely noted absence of corroborating opinions and is a permissible factor under regs | Held: No new rule; noting absence of other opinions is permissible under 20 C.F.R. §404.1527(c)(3,6) |
| Whether ALJ improperly discounted opinion for lack of objective support | Ellars: Objective evidence does support limitations | ALJ: Objective testing (PFTs, cardiac/vascular studies, neurologic exams) did not corroborate extreme limits | Held: Substantial evidence supports ALJ’s conclusion that objective record did not corroborate Dr. Schall’s restrictions |
| Whether ALJ improperly disregarded treating-source special deference | Ellars: ALJ ignored rule that treating opinions get special deference | ALJ: Treater’s opinion receives controlling weight only if well-supported and consistent; it need not be accepted if conclusory/unsupported | Held: ALJ applied proper standards (considering supportability, consistency, specialty) and offered adequate explanation |
Key Cases Cited
- Cutlip v. Sec. of Health and Human Servs., 25 F.3d 284 (6th Cir.) (standard of review: substantial evidence and correct legal standards)
- Buxton v. Halter, 246 F.3d 762 (6th Cir.) (treating physician opinions generally entitled to greater weight)
- Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir.) (treating-source rule and weight of treating opinions)
- Gayheart v. Comm’r of Soc. Sec., 710 F.3d 365 (6th Cir.) (treating-source controlling weight requires supportability and consistency)
- Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir.) (ALJ must give "good reasons" for discounting treating opinion)
- Teague v. Astrue, 638 F.3d 611 (8th Cir.) (check-box forms without explanation may be given little weight)