George Monroe v. Carolyn Colvin
2016 U.S. App. LEXIS 10907
| 4th Cir. | 2016Background
- Monroe applied for DIB and SSI in October 2007 alleging disability from December 8, 2006 due to uveitis, back pain, breathing and memory problems, anxiety, depression, and blackouts.
- Initial denials occurred in 2008; a 2011 Appeals Council remand directed a new decision addressing specified issues and associate files for all claims.
- Two ALJs issued decisions; the second ALJ found Monroe not disabled through February 7, 2012, the decision at issue was the remand decision.
- Monroe challenged the ALJ’s analysis, including the absence of a function-by-function RFC assessment and inadequate explanation of credibility and medical-opinion weight.
- The district court denied relief; the Fourth Circuit reviews de novo the SSA disability determination and remands when the ALJ misanalyzes RFC or misexplains evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFC analysis must be function-by-function | Monroe argues ALJ failed to perform function-by-function RFC analysis. | Monroe argues adopting RFC without full function-by-function basis is permissible under Mascio. | Remand required for function-by-function RFC analysis. |
| Credibility and weight given to medical opinions | ALJ inadequately explained discrediting Monroe’s testimony and weighted medical opinions without specific reasoning. | ALJ gave weight to certain opinions consistent with the RFC and objective evidence. | ALJ's explanation inadequate; remand to develop adequate narrative and reasoning. |
| Consideration of narcolepsy and sleep apnea | ALJ did not sufficiently assess limitations from narcolepsy and sleep apnea or their episodic effects. | ALJ acknowledged sleep apnea and narcolepsy as severe but treated symptoms as consistent with RFC. | Remand to evaluate function-by-function impacts of narcolepsy and apnea. |
| Effect of vacated prior decision on current claim | Res judicata should treat prior findings as binding. | Res judicata does not attach to non-final, vacated determinations; de novo review appropriate. | AlJ correctly conducted de novo review; vacated prior decision does not bind. |
Key Cases Cited
- Mascio v. Colvin, 780 F.3d 632 (4th Cir. 2015) (requires function-by-function RFC analysis before exertional framing)
- Hines v. Barnhart, 453 F.3d 559 (4th Cir. 2006) (vocational evidence must be based on all record evidence and proper hypotheticals)
- Radford v. Colvin, 734 F.3d 288 (4th Cir. 2013) (necessity of rational bridge between evidence and conclusions)
- Lively v. Secretary of Health and Human Servs., 820 F.2d 1391 (4th Cir. 1987) (res judicata considerations in SSA disability cases)
- Albright v. Commissioner of the Social Security Administration, 174 F.3d 473 (4th Cir. 1999) (Acquiescence ruling considerations on subsequent claims)