Francis v. Commissioner Social Security Administration
414 F. App'x 802
6th Cir.2011Background
- Francis applied for Social Security disability benefits after a work-related fall and chronic pain while employed in maintenance for the University of Tennessee.
- An ALJ denied benefits after weighing medical evidence, treating-source opinions, daily activities, and vocational evidence with the aid of a vocational expert.
- Treating orthopedist Dr. Wakham opined severe functional limitations; other physicians offered more moderate limitations (Dr. Pinzon, Dr. Kennedy, Dr. Killefer).
- The ALJ assigned little weight to Wakham’s opinion, citing inconsistencies with objective evidence, conservative treatment, daily activities, and other physicians’ opinions.
- Francis challenged the ALJ’s handling of treating-source opinions and the credibility of his pain evidence; the district court granted summary judgment for the Commissioner.
- The Sixth Circuit reviews for legal correctness and substantial evidence; it upholds the ALJ’s decision when supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ properly weigh Wakham’s treating-source opinion? | Wakham’s pain-related, severe limitations deserve controlling weight. | ALJ properly weighed Wakham’s opinion against evidence and other physicians. | Yes; substantial evidence supports the ALJ’s weight, with harmless procedural error. |
| Was the ALJ’s rejection of Wakham’s opinion supported by substantial evidence? | ALJ failed to credit severe functional limitations from Wakham. | Record supports moderate limitations; Wakham’s opinions conflicted with evidence and daily activities. | Yes; substantial evidence supports rejection of Wakham’s opinion. |
| Did the ALJ properly account for Francis’s pain and daily activities in assessing disability? | Pain statements indicate disabling condition not reflected in the opinion. | Daily activities and conservative treatment show manageable impairment compatible with work. | Yes; the ALJ’s evaluation was supported by substantial evidence. |
Key Cases Cited
- Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (treating-opinion weight and credibility framework)
- Richardson v. Perales, 402 U.S. 389 (S. Ct. 1971) (substantial-evidence standard)
- Mullen v. Bowen, 800 F.2d 535 (6th Cir. 1986) (substantial-evidence review for ALJ findings)
- Kinsella v. Schweiker, 708 F.2d 1059 (6th Cir. 1983) (substantial-evidence standard reiteration)
- Friend v. Comm’r of Soc. Sec., 375 F. App’x 543 (6th Cir. 2010) (harmless-error exception for treating-opinion procedural issues)
- Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (de novo review of ALJ decision; substantial evidence standard)