Mays v. Colvin, 739 F.3d 569

Ms. Mays applied for disability benefits alleging May 2004 onset and the ALJ found no SGA activity through coverage end.
At step two the ALJ found a severe impairment of low back pain; at step three the listings were not met or equaled.
At step four the ALJ determined a sedentary RFC, rejecting Dr. Chorley’s opinion as not supported by objective evidence and found no past relevant work.
At step five, jobs existed in the national economy; benefits denied; Appeals Council denied review; district court affirmed.
Ms. Mays argued the administrative record was incomplete and that the ALJ failed to properly analyze medical source evidence.
The court addressed the amended page of Dr. Chorley’s report that was not incorporated into the record and related due-process/substantial-evidence challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Incomplete record with amended report	Mays asserts due process deprivation from missing amended page.	SSA contends original page in record; remand for new evidence unnecessary; amended page immaterial.	No prejudicial due-process error; record supported the decision.
ALJ’s evaluation of medical-source evidence	ALJ failed to weigh Dr. Chorley and relied on selective evidence; boilerplate reasoning invalid.	ALJ properly weighed treating opinions per 20 C.F.R. § 404.1527 and considered relevant evidence.	ALJ had substantial evidence and correctly analyzed evidence; no reversible error.

Robinson v. Barnhart, 366 F.3d 1078 (10th Cir. 2004) (factors for weighing treating opinions and consistency with record)
Yount v. Barnhart, 416 F.3d 1233 (10th Cir. 2005) (due process requires prejudice showing)
Glass v. Shalala, 43 F.3d 1392 (10th Cir. 1994) (prejudice required for due-process challenges in SSA cases)
Clifton v. Chater, 79 F.3d 1007 (10th Cir. 1996) (ALJ need not discuss every piece of evidence)
Keyes-Zachary v. Astrue, 695 F.3d 1156 (10th Cir. 2012) (weighing opinions; harmless error when no inconsistency)