Murray v. Colvin, 1:16-cv-02465

Plaintiff Jerome Murray applied for Disability Insurance Benefits on June 27, 2012; application denied initially and on reconsideration.
ALJ held a hearing (Jan. 22, 2015) and found Murray not disabled; Appeals Council denied review, making the ALJ decision final.
ALJ found severe impairments: knee arthritis, degenerative disc disease, obesity, pes planus/heel spur, asthma, torn rotator cuff.
ALJ assessed an RFC for light work with a two-hour sit/stand option, constant use of a cane, no pushing/pulling/kneeling, limited stooping, frequent dominant-hand use, and no mental limitations.
Two treating physicians (and a second opinion) completed forms concluding Murray could sit/stand/walk a combined four hours or less in an 8-hour day.
Magistrate Judge recommended remand because the ALJ gave "little weight" to the treating opinions based solely on the absence of evidence that Murray was bedbound; also noted the Appeals Council misstated the temporal scope of an examining physician (Dr. Bruno) whose report alleged limitations as far back as April 1, 2012.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Evaluation of treating and non-treating medical opinions	Treating physicians opined Murray could sit/stand/walk ≤4 hours; ALJ erred by giving those opinions little weight without adequate explanation	ALJ’s RFC and sit/stand option accommodate limitations; claimant not bedbound so extreme restrictions are unsupported	Remand recommended: ALJ’s rationale (claimant not bedbound) is inadequate; insufficient explanation for rejecting treating opinions and for concluding two-hour position intervals are sustainable
Credibility assessment	Murray challenges ALJ credibility findings as boilerplate and improperly dismissive of symptoms	ALJ cited specific inconsistencies between testimony, treatment records, workers’ comp statements, and examiner observations	No reversible error: ALJ cited specific evidence and did not rely exclusively on boilerplate; credibility finding supported by substantial evidence
Appeals Council consideration of new evidence (Dr. Bruno)	Dr. Bruno’s Oct. 2015 opinion applies retroactively to April 1, 2012 and is new, material evidence the Council mischaracterized as post-dating the ALJ decision	Appeals Council said Dr. Bruno’s opinion was about a later time than the ALJ decision	Appeals Council’s explanation was incorrect; on remand the ALJ should consider Dr. Bruno’s report and any other new, material evidence

Craig v. Chater, 76 F.3d 585 (4th Cir. 1996) (standard that ALJ’s decision must be supported by substantial evidence)
Coffman v. Bowen, 829 F.2d 514 (4th Cir. 1987) (review standard for Social Security determinations)
Hays v. Sullivan, 907 F.2d 1453 (4th Cir. 1990) (court should not reweigh evidence or substitute its judgment for the ALJ’s when substantial evidence supports the ALJ)
Meyer v. Astrue, 662 F.3d 700 (4th Cir. 2011) (discussing Appeals Council consideration of new and material evidence)