Gilbert Martinez v. Commissioner Social Security
663 F. App'x 191
| 3rd Cir. | 2016Background
- Gilbert M. Martinez applied for Supplemental Security Income alleging disability from arthritis, nerve damage, and acid reflux beginning August 19, 2011; application denied and he requested a hearing.
- ALJ held a video hearing (July 23, 2013) and issued an opinion (Aug. 15, 2013) finding a severe right-hand impairment from a childhood gunshot but that Martinez was not disabled under the Listings.
- ALJ found Martinez retained capacity for light work with limitations, could use left hand to compensate, and jobs existed in the national economy he could perform.
- Appeals Council denied review, making the ALJ decision final; Martinez sought district court review, which affirmed the Commissioner; Martinez appealed to the Third Circuit.
- Martinez argued the ALJ ignored probative evidence (post-decision docs), undervalued treating physician opinions, failed to consider or properly reject his testimony and subjective pain, and failed to explain weighing of evidence.
- The Third Circuit reviewed for substantial evidence and affirmed, holding the ALJ adequately considered testimony, properly excluded untimely evidence, and supported RFC and Listings conclusions with substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Consideration of post-hearing medical records | Martinez: ALJ should have considered treating-physician records showing rheumatoid arthritis | Commissioner: Records were not in the administrative record and post-date ALJ decision; Martinez gave no good cause for late submission | Held: ALJ not required to consider those documents; they are not part of the record and do not justify remand (no materiality/good-cause) |
| Weight to treating physician opinions | Martinez: ALJ failed to give proper weight to treating doctors diagnosing RA | Commissioner: ALJ weighed opinions against other medical evidence and testimony | Held: Substantial evidence supports ALJ’s evaluation; ALJ gave adequate reasons for discounting conflicting treating opinions |
| Consideration of claimant’s testimony | Martinez: ALJ failed to expressly consider or credit his testimony | Commissioner: ALJ explicitly evaluated credibility and identified inconsistencies with medical record | Held: ALJ sufficiently considered and discredited portions of testimony where contradicted by evidence; explanation adequate under Burnett |
| RFC and Listings determination | Martinez: Impairments met/equaled Listing criteria and precluded work | Commissioner: Medical record and functional evidence do not meet Listings; Martinez retained capacity for limited light work | Held: Substantial evidence supports ALJ’s RFC and conclusion that impairments did not meet/equal Listings; jobs available in economy |
Key Cases Cited
- Brown v. Astrue, 649 F.3d 193 (3d Cir. 2011) (standard of appellate review of ALJ findings)
- Plummer v. Apfel, 186 F.3d 422 (3d Cir. 1999) (definition of disability and burden standards)
- Ventura v. Shalala, 55 F.3d 900 (3d Cir. 1995) (substantial-evidence standard articulated)
- Hartranft v. Apfel, 181 F.3d 358 (3d Cir. 1999) (deference to ALJ factfinding)
- Stunkard v. Sec'y of Health & Human Servs., 841 F.2d 57 (3d Cir. 1988) (medically determinable impairment requirement)
- Brewster v. Heckler, 786 F.2d 581 (3d Cir. 1986) (five-step sequential evaluation framework)
- Matthews v. Apfel, 239 F.3d 589 (3d Cir. 2001) (administrative record requirement for evidence review)
- Szubak v. Sec'y of Health & Human Servs., 745 F.2d 831 (3d Cir. 1984) (standards for remand based on new evidence)
- Burnett v. Comm'r of Soc. Sec. Admin., 220 F.3d 112 (3d Cir. 2000) (requirements for ALJ credibility explanations)