Jimmy Price v. Michael Astrue, Commissioner
401 F. App'x 985
5th Cir.2010Background
- Price appeals denial of DIB and SSI benefits; district court affirmed ALJ decision upholding denial; ALJ found sufficient RFC to permit substantial gainful activity; ALJ weighed evidence, credibility, and medical opinions; ALJ noted MRI showed only mild degeneration and that Price improved with treatment; vocational expert testimony based on ALJ’s hypothetical supported substantial evidence
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ properly evaluate Price’s credibility | Price’s testimony credible; pain and limitations not fully considered | ALJ reasonably discounted credibility based on medical evidence and activities | Yes, credibility supported by record and given limited weight to inconsistent testimony |
| Did the ALJ properly weigh treating versus non-treating physicians | ALJ overemphasized non-treating opinions over treating doctors | Treating opinions not controlling if contradicted by record | Yes, ALJ reasonably weighed treating and non-treating opinions |
| Was the VE’s hypothetical properly based and sufficient | Hypothetical failed to capture Price’s limitations | Hypothetical appropriately reflected RFC | Yes, VE testimony supported substantial evidence |
Key Cases Cited
- Martinez v. Chater, 64 F.3d 172 (5th Cir. 1994) (standard for substantial evidence review; credibility bridge to decision)
- Brown v. Apfel, 192 F.3d 492 (5th Cir. 1999) (review of ALJ’s weighing of evidence; substantial evidence standard)
- Glomski v. Massanari, 172 F. Supp. 2d 1079 (E.D. Wis. 2001) (ALJ must connect evidence to final determination; credibility considerations)
- Carrier v. Sullivan, 944 F.2d 243 (5th Cir. 1991) (requirement of an accurate and logical bridge between evidence and determination)
- Leggett v. Chater, 67 F.3d 558 (5th Cir. 1995) (ALJ may consider claimant’s daily activities in disability status)