Jenkins v. Astrue, 3:12-cv-00274

This is a district court review under 42 U.S.C. § 405(g) of a Social Security disability denial.
Jenkins, administratrix of the estate of Leo Jenkins, sued after Jenkins died in 2010 challenging the denial.
The ALJ found Jenkins capable of sedentary work and denied benefits on September 14, 2009.
The medical record showed multi-level lumbar disc herniations with left-sided nerve compression.
MRI evidence and treating physician opinions suggested greater functional limitation than the ALJ credited.
Court remands to the Commissioner for further consideration of the medical evidence and credibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly evaluated MRI evidence and credibility	Jenkins contends the MRI showed nerve compression the ALJ misread	Colvin argues the ALJ's credibility assessment was supported by the record	Remand for proper consideration of MRI findings and credibility
Whether urination frequency evidence undermines sedentary-work RFC	Jenkins' urination symptoms were not properly accommodated	No supportive medical evidence for two times per hour urination	Remand to address MRI interpretation and symptom evidence
Whether medical opinions (Dr. Argires, others) were properly weighed	Treating sources supported greater restrictions	The ALJ did not abuse the weight given to medical opinions	Remand to reassess medical opinions in light of MRI data

Pierce v. Underwood, 487 U.S. 552 (1988) (substantial evidence standard guidance)
Consolidated Edison Co. v. N.L.R.B., 305 U.S. 197 (1938) (standard for substantial evidence in administrative decisions)
Brown v. Lindenthal, 845 F.2d 1213 (D.C. Cir. 1988) (describes substantial evidence threshold)
Schmidt v. Sullivan, 914 F.2d 117 (7th Cir. 1990) (courts should not substitute lay medical inference for expert opinion)
Poulos v. Commissioner of Social Security, 474 F.3d 88 (3d Cir. 2007) (explains five-step evaluation and burden-shifting)