Sacilowski v. Saul
959 F.3d 431
| 1st Cir. | 2020Background
- Amanda Sacilowski (filed 2015) alleged disabling chronic migraines and worsening bladder disorders; Relevant Time Period: March 25, 2015–December 20, 2016.
- ALJ found migraines, fibromyalgia, and depression "severe" but concluded RFC allowed a limited range of light work; ALJ found bladder issues "non-severe" and denied benefits.
- VE testified that regular absenteeism (once a month is problematic; four times a month precludes full‑time competitive employment).
- Treating physician Dr. Wilson completed questionnaires and a physical capacity form reporting severe limitations (e.g., sitting 1–2 hrs/day, need to lie down 2–4 hrs/day, >4 absences/month) and coordinated care with neurologists/urologists.
- Magistrate judge recommended remand for further fact‑finding; district court reversed the Commissioner and awarded benefits. The Commissioner appealed; the First Circuit reviewed de novo.
- First Circuit affirmed the district court, holding the record contained "overwhelming" evidence of disability (particularly migraine frequency/severity and worsening bladder symptoms) sufficient to award benefits without further remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a remand for further administrative fact‑finding is required or benefits should be awarded | Award benefits: record already contains overwhelming, uncontradicted evidence of disabling impairments (migraine frequency/severity; bladder worsening; Dr. Wilson's opinions) | Remand: unresolved factual issues (conflicting migraine evidence; bladder severity needs development; treating‑physician opinion lacks adequate support) | Held: Award benefits — record is sufficiently developed and overwhelming evidence requires finding of disability during the Relevant Time Period |
| Whether the ALJ erred in discounting Dr. Wilson’s opinions about absenteeism and functional limits | Dr. Wilson’s longitudinal treatment relationship and multiple questionnaires support his limitations, including >4 absences/month | Commissioner contended Dr. Wilson’s 2016 opinions were inconsistent with his own earlier normal findings and lacked objective support | Held: Court credited Dr. Wilson’s opinions as consistent with the record and treating relationship; no contrary evidence undermines them |
| Whether the ALJ lawfully treated the bladder condition as "non‑severe" and considered its combined effects | Bladder condition worsened in 2016 and, even if "non‑severe" alone, exacerbated overall limitations and absenteeism | ALJ relied on earlier state‑agency opinions (from before 2016 worsening) to deem it non‑severe | Held: ALJ’s reliance on outdated opinions was improper; bladder impairment, when considered with migraines, supports disability finding |
| Whether substantial contrary evidence existed to preclude awarding benefits without remand | No substantial contrary medical evidence directly rebutted claimant’s testimony, VE testimony, or treating‑physician findings | Commissioner pointed to some evidence of Botox benefit and state‑agency RFCs finding ability to do light work | Held: Commissioner’s cited evidence did not directly contradict disabling testimony or Dr. Wilson; it was insufficient to defeat an award of benefits |
Key Cases Cited
- Seavey v. Barnhart, 276 F.3d 1 (1st Cir. 2001) (remand vs. award of benefits standard; "overwhelming" evidence exception)
- Garrison v. Colvin, 759 F.3d 995 (9th Cir. 2014) (awarding benefits when record compels disability finding)
- Purdy v. Berryhill, 887 F.3d 7 (1st Cir. 2018) (weight accorded treating physician opinions under pre‑2017 rules)
- Nguyen v. Chater, 172 F.3d 31 (1st Cir. 1999) (ALJ must apply proper legal standards and consider evidence fairly)
- Freeman v. Barnhart, 274 F.3d 606 (1st Cir. 2001) (burden allocation in five‑step disability evaluation)
- Varney v. Sec'y of Health & Human Servs., 859 F.2d 1396 (9th Cir. 1988) (crediting claimant testimony when record compels award)
- Holohan v. Massanari, 246 F.3d 1195 (9th Cir. 2001) (remand unnecessary when record is fully developed and compels benefits)
- Davis v. Shalala, 985 F.2d 528 (11th Cir. 1993) (court may remand with instructions to award benefits when cumulative evidence establishes disability)
- Gonzalez Maldonado v. Sec'y of Health & Human Servs., 996 F.2d 1209 (1st Cir. 1993) (absence of contrary medical reports undermines ALJ's adverse credibility finding)
- Da Rosa v. Sec'y of Health & Human Servs., 803 F.2d 24 (1st Cir. 1986) (ALJ must make specific findings to discredit claimant testimony)