Haddix v. Commissioner of Social Security
1:14-cv-00012
N.D.W. Va.Jun 16, 2014Background
- Jaime Lynn Haddix applied for DIB and SSI alleging disability from March 31, 2009 due to bipolar disorder, generalized anxiety, PTSD, and medication side effects; state agency denied benefits and ALJ Hugar found her not disabled; Appeals Council denied review.
- Treating/treatment evidence: longitudinal mental-health treatment at United Summit Center (USC) with diagnoses of bipolar I, GAD, PTSD; multiple GAF scores ranging roughly 31–60; periodic crisis admissions and medication management (lithium, risperdal/olanzapine, xanax, trazodone, etc.).
- Plaintiff and her husband testified to marked functional limitations: social avoidance, impulsivity/anger, poor sleep, medication drowsiness, difficulty with ADLs some days, and reliance on husband for daily support.
- ALJ found severe mental impairments but concluded Plaintiff did not meet Listings 12.04/12.06; assigned an RFC for all exertional work but limited to simple, routine, repetitive tasks, no production pace (goal-oriented only), no public contact and only occasional coworker/supervisor contact, and occasional workplace changes.
- Vocational Expert testified that such an RFC left significant national jobs (e.g., kitchen helper, industrial cleaner, marker, mail clerk); ALJ therefore found claimant not disabled.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility of claimant and husband testimony | Haddix argues ALJ selectively discounted testimony and erred in credibility finding | Commissioner argues ALJ reasonably evaluated credibility under Craig/SSR 96-7p and cited inconsistent objective and testimonial evidence | Court held ALJ's credibility determination supported by substantial evidence and not patently wrong; affirmed |
| Medication side effects (drowsiness/sleepiness) | Haddix contends ALJ ignored disabling drowsiness from psychotropics | Commissioner says record documents poor sleep more often than disabling daytime somnolence; only one medical note documents ‘‘sleepy all day’’ and no functional limits shown | Court held ALJ did not err; record lacks objective showing that drowsiness produced serious functional limitations |
| Whether impairments meet Listings 12.04/12.06 (paragraph B) | Haddix contends credible testimony and USC records show marked limits in ADLs, concentration/pace, and social functioning | Commissioner argues ALJ reasonably found paragraph B criteria unmet; burden is on claimant to show medical equivalence | Court held claimant failed to carry burden; no treating/provider opinion or record showing marked limitations, so ALJ’s finding upheld |
| Weight given to non-acceptable medical source opinions and GAF scores | Haddix argues ALJ improperly rejected USC clinicians’ opinions and ignored low GAFs (31–40) | Commissioner notes many USC staff are not "acceptable medical sources," ALJ limited weight to therapist's letter but incorporated its substance into RFC; GAFs alone do not establish work-preclusive limitations | Court found ALJ failed to explain weight for therapist's letter sufficiently but error harmless because RFC incorporated those limitations; GAFs lacked specific work-function findings, so no reversible error |
Key Cases Cited
- Hays v. Sullivan, 907 F.2d 1453 (4th Cir.) (scope of review: substantial evidence and correct law)
- Richardson v. Perales, 402 U.S. 389 (Sup. Ct.) (definition of substantial evidence)
- Shively v. Heckler, 739 F.2d 987 (4th Cir.) (ALJ credibility and demeanor weight)
- Craig v. Chater, 76 F.3d 585 (4th Cir.) (two-step pain/symptom evaluation and factors)
- Burns v. Barnhart, 312 F.3d 113 (3d Cir.) (medication side effects and when drowsiness is disabling)
- Johnson v. Barnhart, 434 F.3d 650 (4th Cir.) (treatment of medication side-effect evidence)
- Gordon v. Schweiker, 725 F.2d 231 (4th Cir.) (need to indicate weight given to relevant evidence)