658 F. App'x 255
6th Cir.2016Background
- Charles Martin applied for Social Security disability benefits based on psychiatric symptoms that began after a tax-fraud conviction and incarceration; SSA denied benefits and the case underwent multiple hearings and remands before a third ALJ decision.
- The ALJ found several severe impairments (including affective and anxiety disorders) but concluded none met Listing criteria and assessed an RFC for medium, unskilled work with ability to respond appropriately to supervision, coworkers, and routine changes.
- The ALJ discounted portions of medical opinions and Martin’s testimony as not entirely credible, and found that Martin could perform jobs existing in significant numbers, leading to a denial of benefits; the Appeals Council denied review and the magistrate judge affirmed.
- On appeal Martin argued (1) the ALJ violated the treating-source rule by failing to treat a 2009 report signed by a nurse practitioner and also by a treating physician (Dr. Pharis) as a controlling treating opinion, and (2) the ALJ failed to explain why parts of non-treating experts’ opinions (marked limitations interacting with the public and sustaining concentration) were omitted from the RFC.
- The Sixth Circuit reviewed de novo for legal error and for whether the ALJ’s factual findings were supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Treating-source rule: whether the ALJ erred by not giving controlling weight to a 2009 report signed by Moss and Dr. Pharis | Martin: The 2009 report is a treating-source opinion (Pharis’s signature) and the ALJ failed to apply the treating-source analysis, requiring remand | Government/ALJ: ALJ gave specific, adequate reasons (lack of objective support, internal inconsistency) for assigning little weight; he considered the required factors even if not labeled controlling | Court: No reversible error — ALJ provided proper reasons and considered required factors; remand not warranted |
| Non-treating source opinions: whether ALJ had to explain omission of specific limitations from RFC (public interaction; concentration) | Martin: ALJ failed to explain why Dr. Joslin’s marked public-interaction limitation and Dr. Rutledge’s concentration limitation were not reflected in RFC | Government/ALJ: Non-treating sources do not trigger the treating-source reasons-giving requirement; ALJ gave specific reasons rejecting Rutledge’s concentration finding and partially credited state reviewers | Court: No error — reasons-giving requirement applies to treating sources only; ALJ explained rejection of Rutledge’s concentration limitation and properly weighed non-treating opinions |
| Credibility and RFC sufficiency: whether ALJ’s credibility findings and RFC are supported by substantial evidence | Martin: ALJ improperly discounted symptom reports and omitted relevant limitations from RFC | Government/ALJ: ALJ reasonably found statements not entirely credible and supported the RFC with record evidence and selective weighting of opinions | Court: Substantial-evidence standard satisfied; ALJ’s credibility findings and RFC supported by record and adequate explanation |
Key Cases Cited
- Smith v. Comm’r of Soc. Sec., 482 F.3d 873 (6th Cir. 2007) (treating-source opinions require objective support to receive controlling weight)
- Warner v. Comm’r of Soc. Sec., 375 F.3d 387 (6th Cir. 2004) (treating opinions get deference only when supported by objective medical evidence)
- Combs v. Comm’r of Soc. Sec., 459 F.3d 640 (6th Cir. 2006) (en banc) (factors ALJ must consider when declining to afford controlling weight to a treating source)
- Gayheart v. Comm’r of Soc. Sec., 710 F.3d 365 (6th Cir. 2013) (ALJ may not apply inconsistent scrutiny to treating vs. non-treating opinions)
- White v. Comm’r of Soc. Sec., 572 F.3d 272 (6th Cir. 2009) (standard of review: ALJ legal error vs. substantial evidence for factual findings)