Garcia v. SSA, Commissioner of
2:18-cv-13487
E.D. Mich.Nov 27, 2019Background
- Mary Garcia applied for Disability Insurance Benefits and SSI, alleging physical and mental impairments (including depression, PTSD, anxiety, diabetes with neuropathy, obesity, asthma) with an alleged onset of June 30, 2012.
- After a hearing with claimant and a vocational expert, the ALJ found Garcia not disabled, concluding she could perform a limited range of light work (simple, routine, repetitive, non-production-paced tasks with occasional public/coworker contact and several physical/environmental restrictions).
- The ALJ found severe impairments including mental disorders and diabetes with neuropathy, but did not find any listings met or equaled; RFC incorporated mental limitations to simple work.
- The ALJ gave little weight to treating psychiatrist Jaswant Purohit, M.D.’s opinion (which described marked and moderate mental limitations), finding it internally inconsistent and not supported by the record.
- The Appeals Council denied review; Magistrate Judge Elizabeth A. Stafford recommended denying Garcia’s motion, granting the Commissioner’s motion, and affirming the ALJ’s decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ violated SSR 96-8p by failing to do a function-by-function mental RFC | Garcia: ALJ did not specifically identify ability to understand/carry out/remember instructions, make work decisions, respond to supervision/coworkers, or handle routine changes | Commissioner: ALJ sufficiently analyzed mental functional domains and incorporated appropriate limits into RFC; no detailed checklist required | Held: ALJ’s analysis was adequate; Garcia waived underdeveloped challenge and ALJ addressed functional abilities in the record |
| Whether ALJ impermissibly "played doctor" by crafting RFC without a medical-source RFC | Garcia: RFC lacked a supporting medical provider assessment and is conclusory | Commissioner: ALJ may weigh medical and non-medical evidence and determine RFC; no requirement to adopt a physician’s RFC verbatim | Held: ALJ did not err; RFC was supported by explanation and record citations; ALJ has responsibility to formulate RFC |
| Whether ALJ violated the treating-physician rule in discounting Dr. Purohit’s opinion | Garcia: ALJ improperly discounted treating opinion and misapplied outdated listing criteria | Commissioner: ALJ gave specific reasons—internal inconsistency and lack of record support—and noted the opinion used prior listing language | Held: ALJ provided adequate reasons for giving little weight to treating opinion; plaintiff waived any further attack on the ALJ’s proffered reasons |
Key Cases Cited
- Gentry v. Comm'r of Soc. Sec., 741 F.3d 708 (6th Cir. 2014) (standards for weighing medical opinions and disability analysis)
- Rogers v. Comm'r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (standard for substantial evidence review)
- Gayheart v. Comm'r of Soc. Sec., 710 F.3d 365 (6th Cir. 2013) ("good reasons" requirement for discounting treating-source opinions)
- McPherson v. Kelsey, 125 F.3d 989 (6th Cir. 1997) (undeveloped arguments are waived)
- Delgado v. Comm'r of Soc. Sec., [citation="30 F. App'x 542"] (6th Cir. 2002) (no per se requirement for detailed function-by-function RFC explanation)
- Rudd v. Comm'r of Soc. Sec., [citation="531 F. App'x 719"] (6th Cir. 2013) (ALJ not required to adopt physician's RFC assessment)
- Bass v. McMahon, 499 F.3d 506 (6th Cir. 2007) (review limited to the administrative record)
- Preslar v. Sec'y of Health & Human Servs., 14 F.3d 1107 (6th Cir. 1994) (allocation of burdens in sequential disability evaluation)
- Thomas v. Arn, 474 U.S. 140 (U.S. 1985) (procedural rules concerning objections to magistrate judges' reports)
- Howard v. Sec'y of Health & Human Servs., 932 F.2d 505 (6th Cir. 1991) (procedural waiver principles for objections)