Fletcher v. Colvin
1:16-cv-02830
D. MarylandMay 26, 2017Background
- Plaintiff Kirk Lee Fletcher applied for Disability Insurance Benefits; denied initially and on reconsideration; ALJ held hearing and denied benefits, decision became final when Appeals Council denied review.
- ALJ found severe impairments: bipolar disorder and substance abuse; concluded claimant would be disabled with substance use but, if he stopped substance use, retained RFC for full range of work at all exertional levels with nonexertional limits (simple tasks in 2-hour increments; occasional coworker/supervisor contact; no public contact; simple routine changes).
- ALJ relied on treating and consultative records but attributed many limitations to substance use and assigned moderate weight to a consultative exam that included a GAF of 35.
- Treating physician Dr. Quintero-Howard (monthly treatment 2010–2014) completed opinions indicating marked limitations and absences, noting persistent bipolar symptoms even during periods of sobriety; ALJ discounted those opinions as unexplained.
- Court reviewer found ALJ mischaracterized key records (treating opinion and consultative report showed symptoms during drug-free periods), and identified flaws in the credibility analysis and the RFC/hypothetical regarding concentration, persistence, or pace.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly assessed RFC absent substance use | Fletcher: ALJ failed to account for treating physician’s opinion and misattributed limitations to substance use | Commissioner: ALJ reasonably concluded substance use materially contributed and limited functioning when using | Court: ALJ erred; record shows treating and consultative observations of impairment during drug-free periods; remand required for proper RFC assessment |
| Weight given to treating and consultative opinions | Fletcher: Treating opinion shows marked limits regardless of substance use and was improperly discounted | Commissioner: ALJ permissibly discounted or limited weight due to perceived lack of explanation and substance-use link | Court: ALJ mischaracterized opinions and should have recontacted treating source or better explained basis for discounting; remand ordered |
| Credibility evaluation | Fletcher: ALJ’s credibility findings were inadequate and used language disfavored by Mascio | Commissioner: ALJ’s credibility determination supported by record inconsistencies | Court: Credibility analysis was deficient (including problematic phrasing and limited explanation); on remand ALJ must reassess and explain findings |
| Hypothetical to vocational expert re: concentration/pace (Mascio) | Fletcher: RFC limitation to "simple tasks in 2-hour increments" insufficiently explains ability to sustain work per Mascio | Commissioner: ALJ’s limitation adequately captured claimant’s limits | Court: ALJ should provide fuller justification tying concentration limitation to work-sustaining abilities; remand to clarify RFC and VE hypothetical |
Key Cases Cited
- Craig v. Chater, 76 F.3d 585 (4th Cir.) (substantial-evidence standard for SSA determinations)
- Coffman v. Bowen, 829 F.2d 514 (4th Cir.) (review standard for ALJ factual findings)
- Hays v. Sullivan, 907 F.2d 1453 (4th Cir.) (court may not reweigh evidence; assesses substantial evidence)
- Mascio v. Colvin, 780 F.3d 632 (4th Cir.) (RFC must account for concentration/pace limits and VE hypotheticals must adequately capture those limits)