Maryanne Reynolds v. Commissioner of Social Security
424 F. App'x 411
| 6th Cir. | 2011Background
- Reynolds filed SSI and DIB applications, alleging back and other impairments with obesity; the ALJ denied benefits at Step Four after finding no Listing impairment; Reynolds challenged Step Three and Step Four conclusions; the ALJ found severe back pain and adjustment disorder but did not evaluate physical listings at Step Three; Reynolds’ donut froster work was considered past relevant work; the Appeals Council denied review; the district court affirmed; this court reverses and remands for Step Three analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ err by not evaluating Reynolds’ physical impairments under Listing 1.04 at Step Three? | Reynolds argues the ALJ failed to compare evidence to musculoskeletal listings. | Reynolds did not show listing-level impairment; ALJ properly analyzed 12.04 but skipped 1.00. | Yes; improper Step Three analysis requiring remand. |
| Should obesity have been considered in combination with other impairments? | Obesity and its effects were not adequately considered. | Obesity not raised by Reynolds and thus not necessary to consider. | Merits not dispositive; issue is moot for reversal; remand focused on Step Three. |
| Was the ALJ's treatment of treating physicians’ opinions, including Dr. Khan, reversible error? | ALJ gave insufficient weight to treating opinions. | ALJ provided reasons for not giving controlling weight; reliance on objective evidence. | Harmless error; substantial reasoning supported the outcome. |
| Did the ALJ err in determining Reynolds could perform past relevant work as a donut froster? | Timeframe is ambiguous; past work may not exist. | 15-year guideline applies; job is unskilled and transferable. | Not error; donut froster qualifies as past relevant work. |
Key Cases Cited
- Crum v. Sullivan, 923 F.2d 1137 (6th Cir. 1990) (standard of review for SSA determinations; substantial evidence)
- Youghiogheny & Ohio Coal Co. v. Webb, 49 F.3d 244 (6th Cir. 1995) (substantial evidence standard; need for error-free analysis)
- Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (treating physician weight and credibility factors)
- Burnett v. Comm’r of Soc. Sec., 220 F.3d 112 (3d Cir. 2000) (need for meaningful step-three discussion when impairments may meet/equal listings)
- Clifton v. Chater, 79 F.3d 1007 (10th Cir. 1996) (review of step-three analysis for listing equivalence)
- Senne v. Apfel, 198 F.3d 1065 (8th Cir. 1999) (listing-equal analysis and need for explanation)
- Smith v. Sec’y of Health & Hum. Servs., 893 F.2d 106 (6th Cir. 1989) (credibility and disability evaluation framework)
- Hall v. Comm’r of Soc. Sec., 148 F. App’x 456 (6th Cir. 2005) (credibility and evaluation in SSA proceedings)
- Coldiron v. Comm’r of Soc. Sec., 391 F. App’x 435 (6th Cir. 2010) (treating physician weight and evaluation of medical opinions)
- Nelson v. Comm’r of Soc. Sec., 195 F. App’x 462 (6th Cir. 2006) (procedural adequacy of SSA review)