Ronnie Keeton v. Comm'r of Social Security
583 F. App'x 515
| 6th Cir. | 2014Background
- Keeton applied for social security disability insurance benefits on 12/21/2007 alleging disability from 4/11/2006; SSA denied on 2/8/2008 and again on reconsideration 8/14/2008.
- An administrative hearing occurred 3/12/2010; the ALJ found Keeton not disabled and relied on RFC for medium work with additional limitations.
- Keeton’s impairments include residual effects of a 2000 myocardial infarction with stenting, PTSD, and depression; he had cognitive and concentration limitations affecting work tasks.
- VA awarded 20% disability for diabetes and 70% for PTSD, with unemployability benefits, dated effective 4/11/2006, based on multiple VA assessments.
- District court affirmed the ALJ’s denial; the Sixth Circuit vacated and remanded for reconsideration due to errors in handling medical opinions and treating-source evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| whether the ALJ properly weighed medical opinions | Keeton (Papadakis) opinion entitled to significant weight | ALJ properly weighed treating vs. non-treating opinions | remand required for inadequate reasoning on opinions |
| whether the ALJ neglected treating physicians Sanders and Sehbi | ALJ failed to discuss Sanders and Sehbi and relied improperly on Papadakis | ALJ considered the record; substantial evidence supports decision | remand required for failure to discuss treating sources |
| whether the ALJ properly considered the VA disability determination | VA findings corroborate disability; should be weighed | VA findings not binding and were within the record | remand required; the VA opinion must be properly integrated |
| whether the hypothetical to the vocational expert and RFC reflected credible limitations | Moderate concentration limitations and off-task time not captured | Hypothetical encompassed the credible limitations | remand required to incorporate credible limitations into RFC and VE question |
| whether the credibility assessment was supported by substantial evidence | ALJ erred in discounting PTSD/depression symptoms | ALJ’s credibility finding supported by record | remand required; credibility determination insufficiently explained |
Key Cases Cited
- Beaver v. Sec. of Health, Ed., & Welfare, 577 F.2d 383 (6th Cir. 1978) (credibility and weighing of medical evidence guidance)
- Warner v. Comm’r of Soc. Sec., 375 F.3d 387 (6th Cir. 2004) (credibility and consistency in disability analysis)
- Cole v. Astrue, 661 F.3d 931 (6th Cir. 2011) (need for substantial explanation when rejecting treating source opinions)
- Chenery Corp. v. SEC, 332 U.S. 194 (1957) (agency must set forth reasoning for decisions)
- Blankenship v. Bowen, 874 F.2d 1116 (6th Cir. 1989) (psychological disability assessment permissible with non-perfect data)