Rankin v. Saul, 1:16-cv-01041

Background

Plaintiff Tana Rankin, diagnosed with multiple sclerosis (MS) and right optic neuritis in Dec. 2012, applied for DIB and SSI alleging fatigue, weakness, vision loss, urinary frequency, back pain, anxiety/depression, and cognitive/learning limitations.
ALJ held a hearing (Sept. 2014); denied benefits, finding severe impairments (MS, optic neuritis, anxiety, mood disorder, depression), an RFC for unskilled light work with occasional interaction, and that jobs exist in the national economy.
Plaintiff testified to substantial limitations: naps totaling ~6 hours/day, inability to sit/stand for long periods, frequent urination (every 20–40 minutes), limited lifting (~10 lbs), pain, weakness, memory/reading difficulties; mother gave corroborating testimony.
Medical records show MS diagnosis, some objective findings (T2 lesions, optic atrophy, positive Romberg, slowed fine motor on right), treatment with fingolimod and intermittent improvement; records also document fatigue, urinary frequency (improved over time), and recurrent complaints of low back pain.
Plaintiff appealed to district court arguing the ALJ: (1) improperly assessed her credibility; (2) failed to account for nonexertional MS-related limitations (fatigue, weakness, bladder control, heat sensitivity not in record), literacy/mental limitations, and asthma; (3) inadequately evaluated pain/back pain; and (4) erred at step five. The court reversed and remanded for further consideration at step four.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Credibility of subjective symptoms (fatigue, frequency, naps)	Rankin: ALJ failed to tie credibility findings to all probative medical evidence and mischaracterized or overlooked supporting records	Commissioner: ALJ reasonably found some symptoms unsupported or improved and thus only partially credited	Court: ALJ’s credibility analysis was incomplete; he cited some objective findings but failed to address several symptom domains (fatigue, bladder frequency) and link findings to RFC — remand required
RFC and nonexertional MS limitations (fatigue, weakness, bladder control, balance)	Rankin: ALJ did not evaluate how MS-related nonexertional symptoms affected RFC or explain omission despite recognizing MS as severe	Commissioner: Limiting to unskilled light work accommodates mental and literacy limits; MS symptoms were improved	Court: ALJ erred by failing to analyze or explain how fatigue, weakness, and urinary symptoms (even if improved) affect RFC; must reassess and explain on remand
Pain / low back pain evaluation	Rankin: ALJ did not apply Luna factors or adequately analyze her chronic back pain complaints and related records	Commissioner: ALJ’s treatment of medical opinions and symptom evidence was adequate	Court: ALJ failed to apply the required pain analysis (Luna factors) and did not cite or reconcile multiple treatment notes reporting back pain — remand for explicit pain credibility findings and record citations
Step five vocational finding (jobs in national economy)	Rankin: Because RFC was unsupported, step five finding was premature	Commissioner: ALJ met burden without a VE by relying on RFC and occupational base	Court: Court declined to decide step five because RFC is inadequately supported; remand instructed to resolve RFC issues first

Key Cases Cited

Barnhart v. Walton, 535 U.S. 212 (disability must last 12 continuous months)
Lax v. Astrue, 489 F.3d 1080 (court will not reweigh evidence on substantial-evidence review)
Clifton v. Chater, 79 F.3d 1007 (ALJ must discuss uncontroverted evidence he rejects and significantly probative evidence)
Clark v. Barnhart, [citation="64 F. App'x 688"] (ALJ must consider MS-related limitations such as chronic fatigue)
Luna v. Bowen, 834 F.2d 161 (framework for evaluating pain allegations)
Keyes-Zachary v. Astrue, 695 F.3d 1156 (factors for evaluating symptom intensity and effect)
Maes v. Astrue, 522 F.3d 1093 (ALJ’s duty to develop the record)