Remias v. Commissioner of Social Security
690 F. App'x 356
| 6th Cir. | 2017Background
- Remias applied for disability insurance and SSI in 2010, alleging disability beginning May 21, 2010; SSA denied benefits and an ALJ denied relief after two hearings; Appeals Council remanded once and later declined review; district court affirmed the denial.
- Primary medical evidence included treating physicians Dr. Larry Cowan and Dr. Shelby Raiser, an examining psychologist Dr. Marc Miller, a clinical social worker Dennis Bowers, and two state reviewing psychologists.
- Treating sources opined severe, work‑preclusive limitations (including inability to work with public, in stress, or remember procedures); a reviewing psychologists concluded she could do low‑stress work with limited social interaction.
- ALJ discounted Remias’s subjective testimony based on treatment records (focused on family issues), lack of psychiatric hospitalizations, statements that medication helped, and inconsistencies about panic-attack frequency and babysitting grandchildren.
- ALJ gave little weight to treating physicians’ opinions as unsupported by the record and dependent on Remias’s subjective complaints; gave little weight to non‑physician and examiner opinions that relied on subjective reports; credited state reviewers who found capacity for low‑stress work.
- Sixth Circuit reviewed de novo legal questions and for substantial evidence the ALJ’s findings, and affirmed the district court’s judgment denying benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility of claimant's testimony | Remias: ALJ improperly discounted her testimony about psychological limitations | ALJ: treatment records, lack of hospitalization, improvement on meds, and inconsistencies undermine credibility | Court: ALJ’s credibility finding supported by substantial evidence |
| Weight to treating physicians' opinions | Remias: ALJ failed to give controlling weight to Drs. Cowan and Raiser | ALJ: opinions unsupported by clinical records; Raiser not a psychologist; Raiser’s disability determination reserved to Commissioner | Court: ALJ provided good reasons; substantial evidence supports discounting those opinions |
| Evaluation of examining psychologist and social worker | Remias: ALJ misweighed Dr. Miller and Mr. Bowers who found marked/extreme limitations | ALJ: Miller’s findings internally inconsistent and relied on subjective complaints; Bowers relied heavily on claimant’s reports and unsupported by records | Court: ALJ reasonably discounted both opinions |
| Reliance on state reviewing psychologists | Remias: reviewers didn’t review all records so their opinions are unreliable | ALJ: reviewers’ conclusions are consistent with overall record | Court: ALJ permissibly credited reviewers; their conclusions were supported by record as a whole |
Key Cases Cited
- Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir.) (substantial-evidence standard and scope of review)
- Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir.) (deference to ALJ credibility findings)
- Gayheart v. Comm’r of Soc. Sec., 710 F.3d 365 (6th Cir.) (treating‑source controlling‑weight and "good reasons" rule)
- Bass v. McMahon, 499 F.3d 506 (6th Cir.) (disability determination is reserved to the Commissioner)
- Francis v. Comm’r of Soc. Sec. Admin., [citation="414 F. App'x 802"] (6th Cir.) (ALJ detailing reasons for discounting treating opinion)
- McGrew v. Comm’r of Soc. Sec., [citation="343 F. App'x 26"] (6th Cir.) (permissible reliance on state agency opinion even if not all evidence reviewed)