Sheffield v. Commissioner of Social Security
3:16-cv-00580
| N.D. Ohio | Dec 28, 2016Background
- Plaintiff Robin Sheffield applied for DIB and SSI; ALJ denied benefits and found she could perform light work, including past jobs as housekeeping cleaner and line packer.
- ALJ found severe impairments: angina, hypertension, IBS, lumbar facet degeneration, mood and anxiety disorders, and obesity; RFC limited to light work with postural and reach limits, no ladders, and simple routine tasks.
- Sheffield presented a confirmed fibromyalgia diagnosis from rheumatologist Dr. Kevin Hackshaw (tender point testing: >11/18 painful sites; antalgic gait) and follow-up visits showing worsening pain and recommendation of a rolling walker.
- Other examiners (Dr. Torello and Dr. Iskander) documented antalgic gait and pain behaviors despite normal strength and range of motion; consultative and treating notes supported subjective pain complaints.
- ALJ minimized the fibromyalgia findings (not treating it as a severe impairment), discounted need for an assistive device, and made adverse credibility findings without adequately analyzing the tender point evidence and treating rheumatologist’s findings.
- Magistrate Judge recommended reversal and remand because the ALJ’s decision was not supported by substantial evidence, primarily for failing to properly evaluate the fibromyalgia diagnosis and related credibility/RFC issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred at Step 3 by failing to find listing-level impairment (§1.04) | Sheffield: ALJ failed to evaluate whether impairments meet or equal a listing | Commissioner: ALJ’s Step 3 finding was reasonable based on record | Court: Remand recommended — ALJ’s articulation at Step 3 insufficient for meaningful review |
| Whether ALJ erred at Step 4 by omitting limitations (sitting/standing/walking per Dr. Torello; mental limits per Dr. Speakman) | Sheffield: RFC omitted treating/consultative examiners’ specific functional limits | Commissioner: RFC accounted for limitations; substantial evidence supports RFC | Court: Remand recommended — ALJ failed to adequately address treating/consultative findings, affecting RFC |
| Whether ALJ properly assessed credibility and fibromyalgia evidence under Sixth Circuit precedent | Sheffield: ALJ disregarded rheumatologist’s tender-point diagnosis and failed to apply pain standard; credibility not based on full record | Commissioner: Objective findings (ROM, strength) justify discounting subjective complaints and need for assistive device | Court: Remand recommended — ALJ improperly minimized treating rheumatologist’s tender-point findings and did not meaningfully evaluate credibility in fibromyalgia context |
Key Cases Cited
- Buxton v. Halter, 246 F.3d 762 (6th Cir. 2001) (standard of substantial-evidence review for ALJ findings)
- Rogers v. Commissioner of Social Security, 486 F.3d 234 (6th Cir. 2007) (analysis of fibromyalgia and weight to treating rheumatologist opinions)
- Reynolds v. Commissioner of Social Security, [citation="424 F. App'x 411"] (6th Cir. 2011) (ALJ must evaluate evidence, compare to listing criteria, and explain conclusion at Step 3)
- Felisky v. Bowen, 35 F.3d 1027 (6th Cir. 1994) (two-step pain analysis and factors for assessing credibility)
- Sarchet v. Chater, 78 F.3d 305 (7th Cir. 1996) (difficulty of diagnosing fibromyalgia; lack of objective tests)
- Sullivan v. Zebley, 493 U.S. 521 (U.S. 1990) (claimant bears burden to demonstrate that impairments meet all listing criteria)