Knight Ex Rel. P.K. v. Colvin
756 F.3d 1171
| 10th Cir. | 2014Background
- Dawn Knight appeals a district court denial of SSIB for her daughter P.K. in 2007-2010 proceedings.
- The ALJ found P.K. had hearing loss, a reading disorder, and ADHD, but not a listed impairment.
- Contrary evidence included Hogares therapy notes and treating psychiatrist Dr. Hall’s opinions.
- The ALJ discounted Dr. Hall’s opinions and found only a marked limitation in interaction with others.
- The Appeals Council denied review, and the district court adopted the magistrate’s recommendation to dismiss; the appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility determination for parent testimony | Knight’s testimony lacked proper credibility analysis | ALJ credibility found credible only to extent consistent with non-disabled finding | Reversed for proper credibility analysis |
| Weight given to treating physician Dr. Hall | ALJ inadequately weighed Hall’s opinions | Hall’s opinions were less persuasive for reasons stated | Remanded for proper weight assessment under 20 C.F.R. § 404.1527/416.927 |
| Functional domain of interaction and relating with others | Hall’s opinion of extreme impairment should control | ALJ discounted opinions based on other evidence | Remanded for proper analysis of Hall’s opinion in this domain |
| Caring for herself domain assessment | Evidence of suicidal ideation and medication noncompliance show greater impairment | Therapy addressed ideation; evidence insufficient | Remanded to reassess the caring-for-hself domain with complete record |
| Overall functional-equivalence framework and “whole child” approach | ALJ failed to apply the domain-based and interactive effects properly | Court should defer to ALJ’s domain evaluations | Remanded to reevaluate under functional equivalence and Whole Child approach |
Key Cases Cited
- Barnett v. Apfel, 231 F.3d 687 (10th Cir. 2000) (standard of review; substantial evidence requirement)
- Langley v. Barnhart, 373 F.3d 1116 (10th Cir. 2004) (treating physician opinion weight and credibility)
- Briggs ex rel. Briggs v. Massanari, 248 F.3d 1235 (10th Cir. 2001) (credibility and related considerations in credibility determinations)
- Raymond v. Astrue, 621 F.3d 1269 (10th Cir. 2010) (credibility findings must be tied to substantial evidence)
- Ingram v. Faruque, 728 F.3d 1239 (10th Cir. 2013) (need for reasoned credibility evaluation and weight of opinions)