Lawson v. Commissioner of Social Security Administration
8:16-cv-01846
D.S.C.Sep 5, 2017Background
- Plaintiff Sherrie Lynette Lawson applied for DIB and SSI alleging disability beginning September 18, 2012; applications were denied and an ALJ found her not disabled in a January 23, 2015 decision.
- ALJ found Lawson had severe impairments: femur fracture status post-surgery, hypertension, obesity, and lumbar degenerative disc disease; did not meet a Listing.
- ALJ assessed an RFC for light work with specific postural limits, ability to stand/walk and sit about six hours each in an 8-hour workday, and some limits on exposure to hazards.
- At step four the ALJ concluded Lawson could perform her past relevant work (computer indexer, data entry, surgical technician) and therefore was not disabled.
- Magistrate Judge Austin recommended affirmance; Lawson objected claiming (1) RFC not supported by substantial evidence and (2) credibility finding improper. District Court reviewed objections de novo and adopted the R&R, affirming the Commissioner.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ’s RFC is supported by substantial evidence | ALJ failed to identify medical findings supporting limitations and did not assess capacity for sustained work activity | ALJ considered full record; RFC is supported by medical exams showing improvement and conservative treatment | ALJ’s RFC supported by substantial evidence; objection rejected |
| Whether the ALJ made a proper credibility determination | ALJ did not give specific reasons supported by record for discounting plaintiff’s testimony | ALJ articulated specific, supported reasons (inconsistent objective findings, improvement after surgery, limited treatment, daily activities) | ALJ’s credibility findings supported by substantial evidence; objection rejected |
Key Cases Cited
- Monroe v. Colvin, 826 F.3d 176 (4th Cir. 2016) (RFC must identify functional limitations and explain symptom evaluation)
- Mascio v. Colvin, 780 F.3d 632 (4th Cir. 2015) (requirement to assess work-related abilities function-by-function)
- Radford v. Colvin, 734 F.3d 288 (4th Cir. 2013) (ALJ must provide a record of basis for ruling and explain credibility/evidence weight)
- Craig v. Chater, 76 F.3d 585 (4th Cir. 1996) (conflicting evidence is for ALJ to resolve; court will not reweigh)
- Hays v. Sullivan, 907 F.2d 1453 (4th Cir. 1990) (standard of review: substantial evidence governs court review)