Kacee Chandler v. Commissioner Social Security
667 F.3d 356
| 3rd Cir. | 2011Background
- Chandler developed reflexive sympathetic dystrophy after a 2006 fall; she previously worked as a bookkeeper, receptionist, and housecleaner, reducing hours in 2007 and stopping work in 2008.
- Chandler applied for DIB/SSI in 2007; the ALJ denied benefits in 2009, finding sedentary RFC with limitations and available jobs.
- Appeals Council denied review; the District Court remanded, finding the RFC unsupported by substantial evidence.
- Dr. Popat (2008) issued a Physical RFC; DeWees (2007, 2009) opined substantial impairment, including inability to sit >30 minutes.
- New post-Popat records and two opinions (Echterling, Menges) arose; the ALJ had not addressed these opinions, and the District Court treated Popat’s report as outdated.
- The Sixth- to seven-page ALJ decision explained the weight given to opinions, incorporated Popat’s RFC, and concluded Chandler was not disabled; the Commissioner prevailed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly relied on Dr. Popat's RFC. | Chandler contends Popat's 2008 RFC should be discounted due to older records. | ALJ may rely on State agency expert and incorporate Popat’s findings. | Yes; ALJ properly relied on Dr. Popat; substantial evidence supports RFC. |
| Whether new evidence after Popat requires remand. | New post-Popat records/opinions undermine the RFC and require remand. | New post-Popat opinions not before the ALJ cannot compel remand; new evidence to be considered via Appeals Council only. | Remand not required; new post-Popat materials considered; Drs. Echterling and Menges not before the ALJ. |
| Whether the ALJ adequately explained the weight of medical opinions. | District Court erred in assuming the ALJ relied improperly on lay opinion. | ALJ provided a six-page rationale detailing weights and credibility. | Yes; the ALJ's explanation was sufficient and supported by substantial evidence. |
| Whether the ALJ properly incorporated DeWees’s non-acceptable medical source opinion. | ALJ erred by relying on DeWees’s 2007 opinion that Chandler could work 20–25 hours. | DeWees’s opinion was considered but not binding; ALJ could rely on Popat and other evidence. | Permissible; ALJ considered DeWees’s opinion and substantial evidence supported the RFC. |
Key Cases Cited
- Matthews v. Apfel, 239 F.3d 589 (3d Cir. 2001) (evidence formed from the administrative record; Appeals Council involvement)
- Hartranft v. Apfel, 181 F.3d 358 (3d Cir. 1999) (RFC as what the individual can still do despite impairments)
- Reefer v. Barnhart, 326 F.3d 376 (3d Cir. 2003) (substantial evidence standard and evaluating evidence)
- Rutherford v. Barnhart, 399 F.3d 546 (3d Cir. 2005) (weight given to medical opinions; credibility assessment)
- Brown v. Astrue, 649 F.3d 193 (3d Cir. 2011) (non-binding nature of treating-source opinions on RFC)