Ronald Miller v. Comm'r of Social Security, 811 F.3d 825

Background

Ronald Miller applied in 2006 for SSDI/Supplemental Security Income alleging left leg/knee/foot problems and later depression; initial ALJ denied benefits in 2008.
Appeals Council vacated and remanded in 2011 directing further development of mental and medical evidence (including consultative exams) because of low GAF scores and RFC concerns.
On remand Miller underwent consultative exams (Dr. Bedia — internal medicine; Dr. Imasa — psychiatry) and had ongoing treatment notes (2009–2011); consultants assigned GAF ≈50 and noted limitations; Dr. Bedia found ability to stand up to six hours with cane use.
A second ALJ (2011) gave significant weight only to a 2006 non‑examining state agency RFC (Dr. Azimi) but found Miller could perform light work with sit/stand up to six hours and walking up to two hours; ALJ discounted treating/examining mental assessments and several GAF scores.
The district court affirmed the Commissioner; the court of appeals vacated and remanded, finding multiple legal errors in the ALJ’s consideration of medical opinions, obesity, GAF/mental‑RFC analysis, and use of non‑examining opinion evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight given to non‑examining state‑agency opinion (Dr. Azimi)	Miller: ALJ improperly gave controlling/significant weight to a non‑examining 2006 opinion that did not account for subsequent treatment.	Commissioner: state‑agency consultants are highly qualified and can be given weight.	Court: Reversed — ALJ erred by relying on a non‑examining opinion without evidence it covered the complete record and by adopting an RFC inconsistent with that opinion.
Consideration of obesity in RFC	Miller: ALJ failed to consider obesity in combination with other impairments per SSR 02‑1p.	Commissioner: reliance on medical opinion that noted obesity suffices.	Court: Remand — the ALJ’s limited discussion and reliance on Azimi leave unclear whether obesity was properly considered.
Treatment of GAF scores and mental RFC	Miller: ALJ improperly discounted consistent low GAF scores and used stale/isolated activity evidence to deny mental limitations.	Commissioner: ALJ permissibly discounted GAFs and relied on other record evidence.	Court: Remand — ALJ gave insufficient reasons for discounting multiple consistent GAF scores and failed to show activities were sustained; SSR 96‑8p not properly applied.
Consideration of evidence outside administrative record (James White credentials / post‑ALJ records)	Miller: district court improperly used internet to resolve identity of James White; post‑decision treatment records should be considered.	Commissioner: district court may reference limited outside materials; post‑decision records are not part of the administrative record and not for substantial‑evidence review.	Court: Remand — district court should not have relied on outside internet evidence to resolve identity; post‑ALJ records not considered here but may be submitted on remand if material and good cause shown.

Key Cases Cited

Gentry v. Comm’r of Soc. Sec., 741 F.3d 708 (6th Cir. 2014) (standard of review; ALJ must apply correct legal standards and be supported by substantial evidence)
Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (treating source rule and weight for non‑examining opinions)
Buxton v. Halter, 246 F.3d 762 (6th Cir. 2001) (definition of substantial evidence)
Cole v. Astrue, 661 F.3d 931 (6th Cir. 2011) (agency rules/regulations must be followed even if ALJ’s conclusion might be justified)
Keeton v. Comm’r of Soc. Sec., 583 F. App’x 515 (6th Cir. 2014) (GAF score significance and evaluation)
Coldiron v. Comm’r of Soc. Sec., 391 F. App’x 435 (6th Cir. 2010) (obesity may be credited where RFCs explicitly account for it)
Gayheart v. Comm’r of Soc. Sec., 710 F.3d 365 (6th Cir. 2013) (claimant activities must be shown to be sustained to negate disability)
Foster v. Halter, 279 F.3d 348 (6th Cir. 2001) (post‑decision evidence: standards for remand under 42 U.S.C. § 405(g))