Kelvin Wells v. Cmsnr of Social Security
690 F. App'x 157
| 5th Cir. | 2017Background
- Kelvin Wells applied for Supplemental Security Income in Sept. 2010 alleging PTSD, depression, back problems, congestive heart failure, and hypertension.
- An ALJ found Wells had severe impairments and had not engaged in substantial gainful activity but concluded his impairments did not meet or equal the Listings and assessed a residual functional capacity (RFC) allowing certain work.
- The Appeals Council denied review, making the ALJ’s decision the Commissioner’s final decision.
- Wells, proceeding pro se, sought district-court review; a magistrate judge issued a report recommending affirmance and the district court adopted it.
- Wells argued on appeal there was no material evidence supporting the denial and also challenged the district court’s refusal to accept a late filing; the Fifth Circuit reviewed for substantial evidence and correct legal standards.
- The Fifth Circuit affirmed: medical records supported the RFC (normal spinal exams, manageable pain, no medication side effects; mental-health findings did not show work-preclusive limitations), and the district court properly enforced a pre-filing sanction that temporarily barred Wells from filing until he paid a $100 fine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether substantial evidence supports denial of benefits | Wells: "no material evidence" supports denial | Commissioner: medical and mental records support RFC to work | Affirmed — substantial evidence supports ALJ's RFC and denial |
| Whether the ALJ erred in evaluating physical impairments | Wells: back and cardiac conditions disable him | Commissioner: exams and records show manageable back pain and no disabling cardiac limits | Affirmed — records compatible with non‑disabling limitations |
| Whether the ALJ erred in evaluating mental impairments | Wells: PTSD/depression/memory problems preclude work | Commissioner: evaluations showed symptoms but not work‑preclusive functional limits | Affirmed — mental symptoms did not significantly interfere with work/daily activities |
| Whether district court erred by refusing late filing opposing R&R due to sanctions | Wells: denied opportunity to oppose R&R | District court: Wells was subject to pre‑filing sanction until fine paid; filing occurred before payment | Affirmed — court properly enforced sanction and could bar filings until fine paid |
Key Cases Cited
- Whitehead v. Colvin, 820 F.3d 776 (5th Cir. 2016) (standard of review for Commissioner decisions)
- Newton v. Apfel, 209 F.3d 448 (5th Cir. 2000) (substantial-evidence and legal-standards review)
- Kane v. Heckler, 731 F.2d 1216 (5th Cir. 1984) (definition of substantial evidence)
- Grant v. Cuellar, 59 F.3d 523 (5th Cir. 1995) (less stringent standards for pro se litigants, but briefing obligations remain)
- Topalian v. Ehrman, 3 F.3d 931 (5th Cir. 1993) (district courts’ discretion in imposing sanctions)
- Baum v. Blue Moon Ventures, LLC, 513 F.3d 181 (5th Cir. 2008) (pre‑filing injunctions to deter vexatious litigation)
- Farguson v. MBank Houston, N.A., 808 F.2d 358 (5th Cir. 1986) (monetary sanctions and enjoining filings)
- Muse v. Sullivan, 925 F.2d 785 (5th Cir. 1991) (declining to review claims arising from other, uncombined applications)