Johnston v. Social Security Administration, 6:15-cv-01244

Frieda Johnston sues for SSI disability benefits, alleging dysautonomia and postural orthostatic tachycardia syndrome.
Initial and subsequent ALJ rulings found Johnston not disabled; Appeals Council denied review after remand.
Record shows frequent syncope/fainting, fatigue, headaches, memory issues, and dependence on medications.
Treating internist Dr. Thompson consistently treated Johnston since 2007 with multiple examinations and opinions.
Dr. Thompson diagnosed dysautonomia with severe functional limitations; Medical Source Statements described sit/stand restrictions and need for breaks.
ALJ on remand discounted Thompson’s opinions, then the district court reversed, awarding SSI benefits from 2006.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ erred in weighing treating-source opinions	Thompson’s opinions should be controlling due to treatment history.	ALJ properly weighed opinions with other evidence and credibility.	Yes; Thompson’s opinions must be given controlling weight or good cause shown.
Whether the RFC adequately accounts for nonexertional impairments	Nonexertional fatigue and dysautonomia limits were not properly incorporated.	RFC reflects nonexertional factors within overall work capacity.	No; RFC failed to incorporate nonexertional fatigue properly.
Whether the ALJ properly evaluated Johnston's credibility	Subjective fatigue and symptoms corroborated by treating physicians were undervalued.	ALJ credibility assessment supported by record and methodology.	No; credibility determination insufficiently substantiated nonexertional effects.
Whether the step-five determination was supported by substantial evidence	RFC and credibility flaws precluded past or other work suitability.	Vocational evidence indicated other work exists in the economy.	Reversed; vocational evidence insufficient given error in weighting Thompson and RFC.

Villa v. Sullivan, 895 F.2d 1019 (5 Cir. 1990) (substantial evidence standard and credibility considerations)
Martinez v. Chater, 64 F.3d 172 (5 Cir. 1995) (framework for evaluating disability findings)
Hollis v. Bowen, 837 F.2d 1378 (5 Cir. 1988) (substantial evidence review and credibility)
Perez v. Barnhart, 415 F.3d 457 (5 Cir. 2005) (compare treating opinion weight and use of VE testimony)
Anthony v. Sullivan, 954 F.2d 289 (5 Cir. 1992) (burden-shifting framework in five-step evaluation)