Gobbel v. Commissioner of Social Security Administration
9:19-cv-02131
| D.S.C. | Aug 18, 2020Background:
- Plaintiff Patricia Ann Gobbel applied for Supplemental Security Income; an ALJ denied benefits, finding she retained the RFC for light work with additional restrictions.
- ALJ found multiple severe impairments including migraines, fibromyalgia, spine disorder, PTSD, anxiety, and attention deficit disorder.
- The ALJ limited Gobbel to "simple, limited, and repetitive tasks, but not at a production rate pace," occasional supervisor/public contact, frequent coworker contact, simple instructions/decisions, and Reasoning Level 2.
- The Appeals Council denied review, making the ALJ’s decision the Commissioner’s final decision; Gobbel sought district-court review.
- The Magistrate Judge recommended reversal and remand, concluding the ALJ failed to adequately account for moderate limitations in concentration, persistence, and pace (CPP) in the RFC—noting that simple work limits do not necessarily address ability to stay on task (citing Mascio).
- Neither party filed objections to the Magistrate Judge’s Report; the district court adopted the Report, reversed the Commissioner, and remanded for further administrative proceedings.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ’s RFC adequately accounted for moderate limitations in concentration, persistence, and pace | ALJ’s RFC (simple, limited, repetitive tasks; other limits) did not address Gobbel’s moderate CPP limits and inability to remain on task | ALJ’s adopted restrictions sufficiently accommodated CPP limitations by limiting to simple, non-production-paced tasks and minimal social demands | Court adopted Magistrate’s view: RFC did not properly account for moderate CPP limitations; reversal and remand required (simple-work limits do not equal ability to stay on task) |
| Whether district court must independently review the Magistrate Judge’s Report absent objections | Gobbel did not object; favors adoption | Commissioner did not object | Court applied ‘‘no clear error’’ standard, found none, and accepted the Report; reversed and remanded |
Key Cases Cited
- Mascio v. Colvin, 780 F.3d 632 (4th Cir. 2015) (holding that a limitation to simple work does not necessarily address moderate limitations in concentration, persistence, and pace)
- Meyer v. Astrue, 662 F.3d 700 (4th Cir. 2011) (explaining Appeals Council denial makes ALJ decision the Commissioner’s final decision)
- Higginbotham v. Barnhart, 405 F.3d 332 (5th Cir. 2005) (similar principle that Appeals Council denial yields Commissioner’s final decision)
- Mathews v. Weber, 423 U.S. 261 (1976) (Magistrate Judge issues nonbinding recommendations; district court makes final determination)
- Camby v. Davis, 718 F.2d 198 (4th Cir. 1983) (district court need not conduct de novo review absent timely objections)
- Diamond v. Colonial Life & Acc. Ins. Co., 416 F.3d 310 (4th Cir. 2005) (when no objections filed, district court must determine there is no clear error on the face of the record)