Paula Felton-Miller v. Michael Astrue
459 F. App'x 226
4th Cir.2011Background
- Felton-Miller appeals the district court's affirmation of the SSA denial of Disability Insurance Benefits and Supplemental Security Income.
- The Commissioner uses a five-step framework to evaluate disability; claimant bears burden through step four, with shift at step five.
- The ALJ found Felton-Miller had a severe impairment and evaluated her subjective pain under Craig v. Chater's two-step pain analysis.
- The ALJ concluded Felton-Miller's sarcoidosis, joint/muscle problems, carpal tunnel, and degenerative disc disease were not persistent or equally disabling.
- The ALJ assessed Felton-Miller's residual functional capacity (RFC) without an examining medical expert and found it supported by the record.
- Felton-Miller challenged the ALJ's handling of pain credibility, RFC, and mental RFC under the SSA regulations and case law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly assessed Felton-Miller's pain credibility | Felton-Miller argues Craig controls credibility once impairment evidence exists. | Allegations rely on Craig, but ALJ evaluated all evidence and not solely claimant's statements. | No reversible error; substantial evidence supports the ALJ's credibility ruling. |
| Whether the RFC was supported by substantial evidence without an expert medical opinion | ALJ as layperson erred in formulating RFC without an expert opinion. | RFC can be based on record evidence, medical opinions, and claimant's testimony; no expert needed. | RFC supported by substantial evidence; no requirement for an expert opinion. |
| Whether the ALJ properly evaluated Felton-Miller's sarcoidosis and related functional limitations | ALJ ignored persistent joint inflammation and treatment details suggesting greater limitations. | Record shows non-persistent symptoms and no functional loss beyond established RFC. | Substantial evidence supports the ALJ's assessment; sarcoidosis alone does not establish disability. |
| Whether the ALJ correctly assessed Felton-Miller's mental RFC using the PRT framework | ALJ did not apply the Psychiatric Review Technique (PRT) findings in step three/mental RFC. | ALJ discussed depressive disorder as severe at step two and analyzed four functional areas at step three. | Mental RFC assessment complied with regulations; substantial evidence supports the finding. |
Key Cases Cited
- Craig v. Chater, 76 F.3d 585 (4th Cir. 1996) (two-step pain analysis used for credibility and symptom evaluation)
- Bowen v. Yuckert, 482 U.S. 137 (1987) (step-wise framework and de minimis severity concept)
- Gross v. Heckler, 785 F.2d 1163 (4th Cir. 1986) (functional loss required beyond diagnosis)
- Pleasant Valley Hosp. v. Shalala, 32 F.3d 67 (4th Cir. 1994) (failure to raise issue results in review waiver)
- Gordils v. Sec. of Health & Human Servs., 921 F.2d 327 (1st Cir. 1990) (bare medical findings must be interpreted in terms of RFC by experts)
- Johnson v. Barnhart, 434 F.3d 650 (4th Cir. 2005) (substantial evidence standard; defer to Commissioner when reasonable minds differ)