413 F. App'x 856
6th Cir.2011Background
- Parks applied for disability insurance and SSI after a June 2005 heart attack and subsequent bypass surgery, claiming disability before turning 55 in February 2007.
- An ALJ found Parks disabled as of February 13, 2007 (his 55th birthday) but not disabled before that date; the district court affirmed.
- Parks worked as a coal-truck driver and heavy equipment operator; his work history includes both skilled and heavy labor.
- Medical history includes an August 2003 evaluation showing mild coronary-artery disease with no exertional limits, and a June 2005 CABG followed by a return-to-work attempt that failed due to chest pain and ongoing symptoms.
- Multiple physicians (Harville, Doiron, Boll) provided post-surgery restrictions and opinions; SSA consultative exams (Baez-Garcia, Gregg, Wortz) suggested varying exertional limits, leading to conflicting assessments.
- Parks’s age, education, and work experience, including long-term heavy labor, were considered in determining medical-vocational eligibility before February 2007.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly weighed treating-source opinions | Parks argues treating sources were improperly discounted | ALJ gave valid reasons consistent with record | Yes; ALJ's weighting supported by substantial evidence |
| Whether § 404.1562 was misapplied | Parks contends § 404.1562 should apply due to education and years of arduous labor | Record does not meet § 404.1562 criteria | No; § 404.1562 not applicable |
| Whether the VE’s hypothetical accurately portrayed impairments | Hypothetical omitted limitations from Drs. Wortz and Spangler | Hypothetical included credible limitations accepted by the ALJ | Yes; hypothetical accurately portrayed credible impairments |
Key Cases Cited
- Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (treating-physician rule and need for reasons in discounts)
- Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (treating-source weight factors and credibility)
- Cruse v. Comm’r of Soc. Sec., 502 F.3d 532 (6th Cir. 2007) (burden shifting at steps and substantial-evidence standard)
- Casey v. Sec’y of Health & Hum. Servs., 987 F.2d 1230 (6th Cir. 1993) (hypothetical limitations must reflect credible impairments)
- Ealy v. Comm’r of Soc. Sec., 594 F.3d 504 (6th Cir. 2010) ( VE testimony may support disability finding when hypothetical credible)