Johnson v. Commissioner of Social Security
652 F.3d 646
6th Cir.2011Background
- Pete Johnson seeks disability benefits; ALJ denied.
- Treating pain specialist Dr. Rayes-Prince opined disabling limitations; treating physician’s opinion at issue.
- Non-treating state agency physician Dr. Guerrero prepared an RFC finding crediting lighter work.
- ALJ credited Dr. Guerrero over Dr. Rayes-Prince, giving less weight to the treating source.
- Court vacates district court decision, holds treating physician's opinion supported by objective evidence, remands with instruction to award benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the treating physician's opinion should be controlling | Johnson's treating physician's opinion is well-supported by objective evidence | ALJ properly weighed opinions under 20 C.F.R. § 404.1527(d)(2) | Yes; treating opinion should be controlling weight |
| Whether ALJ adequately evaluated Dr. Rayes-Prince's notes vs Dr. Guerrero's RFC | ALJ mischaracterized notes and erred in discounting Rayes-Prince | ALJ properly weighed conflicting medical opinions | No; ALJ's reasons insufficient; remand warranted |
Key Cases Cited
- Wilson v. Comm'r of Soc. Sec., 378 F.3d 541 (6th Cir.2004) (automatic deference to ALJ findings; regulating weight of opinions)
- Blakley v. Comm'r of Soc. Sec., 581 F.3d 399 (6th Cir.2009) (must follow treating physician weighting rules)
- Valley v. Comm'r of Soc. Sec., 427 F.3d 388 (6th Cir.2005) (substantial evidence review; deference to ALJ findings)
- Smith v. Halter, 307 F.3d 377 (6th Cir.2001) (credibility and evaluation of symptom testimony)
- Longworth v. Comm'r Soc. Sec. Admin., 402 F.3d 591 (6th Cir.2005) (substantial evidence standard and review framework)