Mooney v. Social Security Administration, Commissioner of
2:11-cv-00056
E.D. Tenn.Jan 17, 2012Background
- Mooney, 37, high school education, applied for DIB and SSI under the Social Security Act; claims disability due to heart/aortic disease, spine degenerative disease, kidney disease, COPD, and mental impairment.
- ALJ denied benefits; both parties filed dispositive motions; magistrate reviews for substantial evidence under 28 U.S.C. § 636.
- The court must determine if the Secretary’s findings are supported by substantial evidence and align with SSA regulations.
- ALJ found severe impairments: aortic valve disease/ascending aneurysm and degenerative disc disease; RFC determined as full range of light work.
- Medical record includes extensive cardiology, renal cancer history (nephrectomy), COPD, back/neck pain, mood/anxiety disorders, and substance use history, with multiple treating and consulting sources.
- Dr. Schacht and Dr. Blickenstaff testified at the hearing; the ALJ gave weight to their opinions and found no severe mental impairment beyond drug dependence, relying on Grid rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the RFC supported by substantial evidence? | Mooney asserts the record shows a severe mental impairment precluding light work. | Commissioner contends the record supports a full range of light work after evaluating opinions of experts and drug-use impact. | Yes; substantial evidence supports the RFC for light work. |
| Did the ALJ properly determine the mental impairment is not severe? | Mooney argues there is a functional mental impairment beyond drug dependence that is severe. | Commissioner relies on Dr. Schacht/Lawhon/Jones and finds no severe mental impairment beyond substance abuse. | Yes; substantial weight to expert opinions supports no severe mental impairment. |
| Did the ALJ properly weight treating sources vs. consultative/expert opinions? | Mooney claims treating sources (e.g., Dr. Kodali) should be given controlling weight where appropriate. | ALJ appropriately weighed conflicting evidence and gave greater weight to certain consultative/expert opinions. | Yes; ALJ’s weighing of Dr. Kodali vs. Schacht/Blickenstaff and others was supported by the record. |
| Was the use of the Medical-Vocational Grid appropriate given the RFC? | If a severe mental impairment existed, Grid would require vocational expert analysis over a generic RFC. | Because no severe mental impairment is established, Grid correctly determines non-disability. | Yes; Grid usage was appropriate given the RFC and lack of a severe mental impairment. |
| Did the ALJ credibly assess the credibility of Mooney’s pain and functional limitations? | Plaintiff alleges disabling pain and functional limits unsupported by the record. | ALJ found Plaintiff not credible to the extent statements were inconsistent with full-light-work capacity. | Yes; credibility assessment supported by objective findings and other medical opinions. |
Key Cases Cited
- McCormick v. Secretary of Health & Human Services, 861 F.2d 998 (6th Cir. 1988) (substantial evidence standard governs SSA review)
- Richardson v. Perales, 402 U.S. 389 (Supreme Court 1971) (substantial evidence standard of review)
- Consolo v. Federal Maritime Comm., 383 U.S. 607 (1966) (limits de novo fact-finding in SSA review)
- Garner v. Heckler, 745 F.2d 383 (6th Cir. 1984) (credibility and factual conflicts resolved by the Commissioner)
- Listenbee v. Secretary of Health and Human Services, 846 F.2d 345 (6th Cir. 1988) (defining substantial evidence in SSA review)
- Bowen v. Comm’r of Soc. Sec., 478 F.3d 742 (6th Cir. 2007) (administrative error prejudices claimant when regulations not followed)
- Higgs v. Bowen, 880 F.2d 860 (6th Cir. 1988) (de minimis severity standard for step-two threshold)