Reynolds v. Commissioner of Social Security
14 F. Supp. 3d 954
S.D. Ohio2014Background
- Plaintiff seeks review of the Commissioner’s denial of Social Security disability benefits under 42 U.S.C. § 405(g).
- Magistrate Judge Newman recommended reversing and remanding for an immediate award of DIB with an onset date of January 23, 2003.
- The Court adopted the Magistrate Judge’s recommendation, overruled the Commissioner’s objections, and ordered judgment in Plaintiff’s favor for benefits with an onset date of January 23, 2003.
- ALJ Lombardo’s RFC relied heavily on Dr. Smith, a treating physician who later acted as a consultative examiner, creating a potential conflict of interest.
- Appeals Council remand directed evaluation of all medical opinions in light of the treating relationship with Dr. Smith; the Court found the ALJ did not comply with this directive.
- The Court found the treating-physician opinions from Drs. Cole, Tambrini, and Watson were not given proper weight under the good-reasons rule.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred by relying on Dr. Smith despite the preexisting treating relationship. | Lombardo relied on Smith despite conflict with prior treatment. | Smith’s opinion was substantial evidence supporting the RFC. | Yes; error to rely on Smith given conflict. |
| Whether the weight given to treating physicians violated the treating physician rule and good reasons requirement. | Treating physicians Cole, Tambrini, and Watson should be given controlling weight or proper weight with good reasons. | Smith's opinion justified the RFC; treating opinions appropriately weighed. | Yes; the weight given to treating physicians was inadequate and not well explained. |
| Whether the ALJ complied with the remand order requiring evaluation of all medical opinions in light of the treating relationship with Dr. Smith. | ALJ failed to re-evaluate all medical evidence with the conflict in mind. | ALJ’s analysis was consistent with the remand decision. | No; ALJ failed to follow the remand directive. |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (1971) (substantial evidence standard; judicial review of SSA decisions)
- NLRB v. Columbian Enameling and Stamping Co., 306 U.S. 292 (1939) (evidence standard; role of credibility and fact-finding)
- LeMaster v. Secretary of Health and Human Services, 802 F.2d 839 (6th Cir.1986) (substantial evidence framework in SSA reviews)
- Buxton v. Halter, 246 F.3d 762 (6th Cir.2001) (zone of choice; substantial evidence review)
- Casey v. Sec’y of H.H.S., 987 F.2d 1230 (6th Cir.1993) (deference to ALJ credibility findings; standard of review)
- Gibson v. Secretary of Health, Education and Welfare, 678 F.2d 653 (6th Cir.1982) (foundational statements on substantial evidence)
- Lashley v. Sec’y of Health and Human Services, 708 F.2d 1048 (6th Cir.1983) (ALJ duty to develop a full and fair record)
- Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir.2004) (treating physician rule and weight considerations)
- Colvin v. Barnhart, 475 F.3d 727 (6th Cir.2007) (regulatory/regulatory framework for RFC and disability determinations)