Rainwater v. Social Security Administration
4:09-cv-00486
N.D. Okla.Jan 21, 2011Background
- Rainwater, age 43, with a tenth-grade education, sought SSI benefits under 42 U.S.C. § 405(g).
- ALJ found Rainwater not disabled from February 6, 2006 through November 5, 2008.
- Impairments include cutaneous T-cell lymphoma, COPD with reactive airways, and depression.
- Medical history includes prior chemotherapy for non-Hodgkin’s lymphoma, asthma/COPD episodes, and limited treatment due to financial barriers.
- Claim proceeded through two hearings (April and August 2008); evaluator relied on consultative and agency opinions to form RFC.
- Appeals Council denied review; district court affirmed the ALJ’s decision as supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly evaluated Rainwater’s credibility | Rainwater argues the ALJ misweighed pain and fatigue testimony and relied on improper factors. | Rainwater’s credibility was adequately assessed using Luna/ Branum framework with substantial evidence. | Credibility supported by substantial evidence; ALJ properly evaluated pain. |
| Whether the ALJ properly weighed medical source and other-source evidence | Rainwater contends the ALJ selectively discounted Family & Children’s Services records and misinterpreted evidence. | ALJ gave proper weight to medical and other sources, including conservative treatment notes and nonmedical evidence. | ALJ’s weighing of evidence was adequate and consistent with law. |
| Whether the RFC adequately accounts for Rainwater’s impairments | Rainwater asserts RFC inadequately reflects her functional limitations from lymphoma, COPD, and mood symptoms. | RFC reflects exertional limits and environmental/exposure restrictions supported by record. | RFC supported by substantial evidence. |
| Whether the hearing process complied with due process and medical evidence development | Rainwater alleges failure to call a medical expert and improper development of evidence. | Two hearings with counsel, later consultative exam, and post-hearing evidence cure any deficiencies. | Hearing complied with due process and evidentiary development. |
| Whether the ALJ properly handled mental-health evidence and GAF discussion | Rainwater challenges weight given to Family & Children’s Services assessment and GAF score. | ALJ adequately discussed the assessment, explained weight, and relied on evidence showing situational depression. | ALJ properly weighed mental-health evidence. |
Key Cases Cited
- Branum v. Barnhart, 385 F.3d 1268 (10th Cir. 2004) (three-prong credibility framework for pain claims; Luna-derived factors)
- Hawkins v. Chater, 113 F.3d 1162 (10th Cir. 1997) (broad latitude in developing medical evidence; standard of review)
- Qualls v. Apfel, 206 F.3d 1368 (10th Cir. 2000) (treatment of 'other source' evidence; weight and discussion required)
- Romero v. Astrue, 242 F. App'x 536 (10th Cir. 2007) (reliance on nonmedical evidence and credibility assessment)
- Cowan v. Astrue, 552 F.3d 1182 (10th Cir. 2008) (credibility factors and treatment consistency considerations)
- Langley v. Barnhart, 373 F.3d 1116 (10th Cir. 2004) (Paragraph B criteria and mental impairment evaluation context)
- Lopez v. Barnhart, 78 F. App'x 675 (10th Cir. 2003) (GAF and interpretation considerations in credibility)