Lucas v. Commissioner of SSA
2:11-cv-00429
| S.D. Ohio | Mar 30, 2012Background
- Plaintiff Ivy McCoy applied for disability benefits and SSI; the ALJ found she could perform light work including past work and other jobs; McCoy died in 2009 after Appeals Council review request; Thomas Lucas sought to pursue SSI on McCoy’s behalf and defendant moved to dismiss for lack of standing; Magistrate Judge recommended dismissal of SSI claim on standing grounds; the core challenges were treating-physician rule application and credibility assessment.
- Procedural posture: the ALJ’s February 2009 decision was adopted as final by the Appeals Council; this action seeks review under 42 U.S.C. §405(g) and cross-motions for summary judgment.
- Key medical history shows degenerative disc disease, lupus, diabetes, obesity, PTSD and generalized anxiety disorder with various treating and examining physicians; substantial evidence in the record supports a residual functional capacity for light work with specific postural and cognitive limitations.
- The ALJ concluded McCoy had mild to moderate functional limitations, could perform past relevant work, and there were jobs in significant numbers in the national economy; the decision rests on weighing treating-source opinions and the credibility of McCoy’s subjective complaints.
- The court must evaluate whether the treating doctors’ opinions were given appropriate weight and whether credibility determinations were properly supported by the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight given to treating-source opinions | McCoy’s treating psychiatrist Dr. Rohrer and treating physician Dr. Tribuzio deserved controlling weight | ALJ properly weighed treating opinions against other substantial evidence | Yes; ALJ offered substantial reasons for not giving controlling weight to Rohrer and Tribuzio. |
| Credibility of claimant’s testimony | McCoy’s subjective complaints supported by objective findings and treatment history | Statements were not fully credible given inconsistencies and medical evidence | Yes; credibility determination supported by substantial evidence. |
| Standing to pursue SSI on behalf of McCoy | Lucas had standing as administrator/representative for McCoy | No standing to pursue Title XVI claim by Lucas | Not explicit in the recommendation; the court’s evaluation treated the standing issue as threshold procedural matter. |
| Residual Functional Capacity and ability to perform work | RFC should reflect greater limitations based on medical evidence | RFC adequately supported by record and medical opinions | Yes; substantial evidence supports the light-work RFC with specified limitations. |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (substantial evidence standard for disability determinations)
- Harris v. Heckler, 756 F.2d 431 (6th Cir. 1985) (credibility and substantial evidence principles in disability cases)
- Duncan v. Secretary of Health and Human Services, 801 F.2d 847 (6th Cir. 1986) (pain evaluation framework and objective evidence requirement)
- Hall v. Bowen, 837 F.2d 272 (6th Cir. 1988) (good reasons required for rejecting treating opinions)
- Wilson v. Commissioner of Social Security, 378 F.3d 541 (6th Cir. 2004) (treating-source weight and evaluation)
- Kirk v. Secretary of Health and Human Services, 667 F.2d 524 (6th Cir. 1981) (data to support diagnosis and controlling weight standards)
- Garner v. Heckler, 745 F.2d 383 (6th Cir. 1984) (broad statements of disability not controlling without data)
- Hensley v. Astrue, 573 F.3d 263 (6th Cir. 2009) (rebuttable presumption treating physician’s opinion deserves deference)