Esin Arakas v. Commissioner, Social Security
983 F.3d 83
| 4th Cir. | 2020Background
- Esin Arakas applied for SSDI in 2010 alleging fibromyalgia, cervical degenerative disc disease, and bilateral carpal tunnel; amended onset date January 1, 2010. Two ALJ hearings (2012, 2017) denied benefits; Appeals Council and district court proceedings produced prior remand; district court later affirmed the 2017 denial. Fourth Circuit review followed.
- Treating rheumatologist Dr. Frank Harper treated Arakas from 1996–2017, repeatedly documented diffuse trigger-point tenderness, chronic pain, fatigue, and cognitive complaints, and submitted three opinion letters concluding she could not sustain full-time work since January 2010.
- Nonexamining state consultants rated Arakas as capable of light work; ALJ (2017) adopted a light-RFC with postural and hazard limitations, found her subjective symptom statements not fully credible, gave Dr. Harper’s opinions little weight, and relied on state consultants to deny disability at step 4 (past work as dining-room manager).
- The ALJ emphasized normal objective findings (full range of motion, absence of joint inflammation) and conservative treatment as reasons to discount symptoms; the court below accepted that analysis.
- Fourth Circuit held the ALJ misapplied legal standards for evaluating subjective symptoms (especially for fibromyalgia), mischaracterized and cherry-picked medical evidence and claimant testimony, and erred in weighing the treating physician’s opinion; the court reversed and remanded with instructions to award benefits and calculate disability payments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ applied proper legal standard to subjective symptom evaluation for fibromyalgia | Arakas: ALJ improperly required objective corroboration and ignored that fibromyalgia symptoms are largely subjective and may be proven solely by claimant testimony and trigger-point findings | SSA: ALJ permissibly considered objective evidence as one factor under 20 C.F.R. § 404.1529/SSR 16-3p | Held: ALJ erred—cannot discount fibromyalgia complaints merely for lack of objective findings; objective normal findings are largely irrelevant and may not be used to raise claimant’s burden. |
| Whether ALJ’s credibility and symptom findings are supported by substantial evidence (including assessment of daily activities) | Arakas: ALJ cherry-picked, misstated record, ignored qualifying statements about limited daily activities and failed to explain how sporadic/light activities show capacity for sustained 8-hr workday | SSA: ALJ permissibly relied on inconsistencies, conservative treatment, and reported activities | Held: ALJ’s findings unsupported—selective citation, factual misstatements, and failure to account for extent/limitation of activities; no logical bridge to RFC. |
| Whether ALJ properly weighed treating physician Dr. Harper’s opinions under the treating-physician rule | Arakas: Dr. Harper’s opinions were well-supported (longitudinal trigger points, MRI, specialty) and not contradicted; entitled to controlling/great weight | SSA: ALJ discounted opinion as based on claimant’s subjective reports and inconsistent with other record evidence | Held: ALJ misapplied treating-physician rule and substituted lay interpretations for medical ones; Dr. Harper’s opinions should have been afforded controlling or at least greater weight. |
| Remedy—remand for further proceedings or immediate payment of benefits | Arakas: Record undisputedly shows inability to sustain full-time work; award benefits | SSA: Errors may warrant remand for further factfinding | Held: Court finds record clearly establishes disability for relevant period and awards benefits (reverse and remand for calculation), concluding further hearing would be pointless and unjust. |
Key Cases Cited
- Hines v. Barnhart, 453 F.3d 559 (4th Cir. 2006) (ALJ may not require objective evidence of pain intensity; claimants can rely on subjective evidence for symptom severity)
- Sarchet v. Chater, 78 F.3d 305 (7th Cir. 1996) (fibromyalgia symptoms are subjective and lack objective diagnostic tests)
- Green-Younger v. Barnhart, 335 F.3d 99 (2d Cir. 2003) (trigger points and longitudinal treating evidence can warrant controlling weight for treating rheumatologist)
- Brosnahan v. Barnhart, 336 F.3d 671 (8th Cir. 2003) (consistent trigger-point findings constitute objective medical evidence of fibromyalgia)
- Lewis v. Berryhill, 858 F.3d 858 (4th Cir. 2017) (ALJ must not improperly increase claimant’s burden when evaluating subjective complaints)
- Coffman v. Bowen, 829 F.2d 514 (4th Cir. 1987) (treating physician’s opinion is entitled to great weight and may be disregarded only if contradicted by persuasive evidence)
- Mascio v. Colvin, 780 F.3d 632 (4th Cir. 2015) (RFC assessment requires identification of functional limitations and ability to sustain regular work)
- Monroe v. Colvin, 826 F.3d 176 (4th Cir. 2016) (ALJ must build an accurate, logical bridge in the decision and provide narrative discussion linking evidence to conclusions)