Monroe-Evans v. Berryhill
Civil Action No. 2016-1081
| D.D.C. | Sep 13, 2017Background
- Monroe-Evans filed a Title II claim alleging disability beginning September 9, 2013 based on right Achilles/tendon problems and other conditions; she had previously received a limited period of disability (Sept. 2010–Nov. 2011).
- SSA denied her claim initially and on reconsideration; an ALJ held a hearing on December 9, 2015 and issued an adverse decision on February 18, 2016.
- The ALJ found severe impairments (Achilles tendonitis, pseudotumor cerebri, obesity, major depression), but concluded Monroe-Evans retained an RFC for limited sedentary work (stand/walk 2 hours, sit 6 hours, lift 10 lbs, no ladders, occasional ramps/stairs and lower-extremity push/pull; simple, routine, repetitive tasks).
- The ALJ found jobs existed in significant numbers in the national economy and denied benefits; the SSA Appeals Council denied review, making the ALJ’s decision final.
- Monroe-Evans argued the ALJ’s RFC was legally flawed in five respects (improper evidence evaluation; overreliance on state-agency and optimistic treating opinions; omission of need for an assistive device; failure to address pseudotumor cerebri limitations; failure to include concentration/pace limitations) and moved for reversal or remand.
- The government’s brief largely restated deference to the ALJ and did not respond to Monroe-Evans’s five specific arguments; the court treated that omission as concession and granted plaintiff’s motion, remanding for award of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of ALJ’s RFC evaluation | RFC omitted several limitations and misstated/ignored evidence; thus unsupported by substantial evidence | RFC is supported by record and ALJ properly assessed credibility and medical evidence | Court found gov’t failed to rebut specific errors; treated them as conceded and reversed/remanded for benefits |
| Weight given to State‑agency and treating opinions | ALJ gave undue weight to state reviewers and a treating physician’s "hopeful prediction" without proper analysis | State‑agency experts are highly qualified and support the RFC | Court found Defendant failed to address the plaintiff’s specific challenge to the weight analysis; deemed conceded |
| Omission of need for assistive device to ambulate | ALJ’s RFC did not account for plaintiff’s need for an assistive device, a material limitation on ambulation | Government did not meaningfully respond to this omission | Treated as conceded; omission contributed to reversal/remand |
| Failure to include limitations from pseudotumor cerebri and concentration/pace | ALJ found pseudotumor cerebri severe but imposed no related RFC limits; no concentration/pace limits were assessed despite evidence | Government did not respond to these points | Treated as conceded; court found the unexplained gaps fatal to the ALJ’s RFC determination |
Key Cases Cited
- Butler v. Barnhart, 353 F.3d 992 (D.C. Cir. 2004) (standard: Commissioner’s decision upheld if based on substantial evidence and correct legal standards)
- Richardson v. Perales, 402 U.S. 389 (Sup. Ct. 1971) (definition of substantial evidence review)
- Rossello ex rel. Rossello v. Astrue, 529 F.3d 1181 (D.C. Cir. 2008) (substantial‑evidence review is highly deferential to the agency)
- Jeffries v. Astrue, 723 F. Supp. 2d 185 (D.D.C. 2010) (court must uphold ALJ’s legal determination if not tainted by legal error)
- Broyles v. Astrue, 910 F. Supp. 2d 55 (D.D.C. 2012) (reviewing court should ensure ALJ analyzed evidence and explained weights assigned)