Masters v. Commissioner of Social Security
707 F. App'x 374
| 6th Cir. | 2017Background
- Mary K. Masters applied for SSI (filed Oct 16, 2012) alleging disability from May 10, 2012; denied administratively and by ALJ (Jan 6, 2015), Appeals Council denied review, district court affirmed, Masters appealed to Sixth Circuit.
- Medical record: diagnoses of fibromyalgia, chronic fatigue, osteoarthritis (knees), migraines, major depressive disorder, generalized anxiety; treatment includes chiropractic visits, cystoscopy for interstitial cystitis (IC), bladder-directed meds, and intermittent pain medications; sparse treatment notes in late 2013–2014.
- Consultative exams: Dr. Naushad Haziq (physical) found normal gait/station and ability to perform basic functions; Dr. Timothy Baggs (psych) identified depressive and anxiety disorders; state psychologists found no significant workplace limitation from mental impairments.
- Treating physician Arden Acob opined Masters was unable to work due to migraines but submitted no supporting treatment records; ALJ gave little weight to Acob’s opinion for inconsistency and lack of records.
- VE testified that, with the ALJ’s RFC, sedentary/unskilled jobs exist; if claimant were off-task 10% daily and missed >2 days/month, no work would exist. ALJ adopted RFC for light work with restrictions and found jobs exist in the national economy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight to treating/examining opinions | Masters: ALJ improperly discounted treating physicians and favored non‑treating examiners, so RFC unsupported | Commissioner: ALJ properly weighed evidence, gave good reasons to discount Acob (no records, inconsistent statements) | Affirmed — ALJ gave valid reasons and substantial evidence supports weight assigned |
| Fibromyalgia & pain standards | Masters: ALJ failed to apply Rogers/Felisky standards for fibromyalgia and pain credibility | Commissioner: ALJ found fibromyalgia severe, applied Felisky factors in assessing pain and RFC | Affirmed — diagnosis alone insufficient; ALJ considered factors and supported conclusions |
| Lay testimony and VE reliance | Masters: ALJ improperly discredited lay testimony and relied on VE answers that did not reflect true limitations | Commissioner: ALJ gave specific, evidence‑based reasons to discount lay testimony; VE hypotheticals matched ALJ‑credited limitations | Affirmed — ALJ permissibly discounted lay testimony and relied on VE for accepted limitations |
| Interstitial cystitis (IC) | Masters: IC alone warrants disability | Commissioner: Record shows IC resolved after cystoscopy; no ongoing severe limitation | Affirmed — substantial evidence supports ALJ’s finding that IC was nonsevere/resolved |
Key Cases Cited
- Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (substantial‑evidence standard explanation)
- Warner v. Comm’r of Soc. Sec., 375 F.3d 387 (6th Cir. 2004) (definition of substantial evidence and credibility considerations)
- Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (standards for assessing fibromyalgia claims)
- Felisky v. Bowen, 35 F.3d 1027 (6th Cir. 1994) (factors for evaluating subjective complaints of pain)
- Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir. 1997) (permissible reasons to discount credibility where inconsistencies exist)
- Smith v. Halter, 307 F.3d 377 (6th Cir. 2001) (VE testimony reliance and limits of appellate review)
- Bogle v. Sullivan, 998 F.2d 342 (6th Cir. 1993) (when treating source opinion may be discounted)
- Casey v. Sec’y of Health & Human Servs., 987 F.2d 1230 (6th Cir. 1993) (ALJ must incorporate only credited limitations into VE hypotheticals)