Mueller v. Commissioner of Social Security
683 F. App'x 365
| 6th Cir. | 2017Background
- Mueller applied for Social Security disability insurance benefits, alleging disability beginning May 30, 2008; SSA denied benefits and an ALJ denied relief; Appeals Council denied review and the district court affirmed.
- Treating psychiatrist Dr. Badshah Maitra opined Mueller would frequently miss work and could not perform consistently/effectively due to mental impairments.
- ALJ gave little weight to Dr. Maitra’s opinion, finding it inconsistent with his treatment notes and other record evidence.
- Record showed Mueller often went months without medication or visits without adverse effects; when symptomatic she responded to medication; examinations were largely unremarkable.
- Mueller completed an undergraduate degree and was on track to finish law school, ranked first in her class, and spent many hours per day on schoolwork.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ gave good reasons for discounting treating psychiatrist’s opinion | Mueller: ALJ failed to give good reasons and should have given controlling weight to Dr. Maitra’s opinion | ALJ: Opinion inconsistent with provider’s notes, treatment gaps, effective medication response, and claimant’s activities | Affirmed: Substantial evidence supports ALJ’s decision to give little weight to the treating opinion |
| Whether Mueller’s mental impairments were severe | Mueller: Impairments are episodic but periodically cause severe symptoms that render her disabled | ALJ: Evidence shows effective treatment, long medication/treatment gaps without adverse effects, and substantial daily functioning | Affirmed: Court held impairments not severe; episodic nature did not undermine this conclusion |
Key Cases Cited
- Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (standard of review: substantial evidence)
- Gayheart v. Comm’r of Soc. Sec., 710 F.3d 365 (6th Cir. 2013) (treating-source opinion controlling-weight and good-reasons rule)
- Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir. 1997) (credibility evaluation principles)
- Despins v. Comm’r of Soc. Sec., 257 F. App’x 923 (6th Cir. 2007) (impairment severity and evidence of functioning)
- Hardaway v. Sec’y of Health & Human Servs., 823 F.2d 922 (6th Cir. 1987) (episodic impairments and severity analysis)