Smith v. Berryhill
Civil Action No. 2015-1521
D.D.C.Sep 18, 2017Background
- Jimmy L. Smith applied in 2012 for Social Security Disability Insurance and Supplemental Security Income, claiming limitations from a heart implant, hypertension, and knee problems.
- SSA denied initial claims and reconsideration; ALJ held a hearing in April 2014 and denied benefits, finding Smith retained a restricted range of sedentary work (RFC) and therefore was not disabled.
- ALJ gave "very little weight" to primary-care Dr. Onyeaghala's opinions and "significant weight" to cardiologist Dr. Burris's physical limitation opinions but discounted legal conclusions (e.g., "permanent disability").
- ALJ found claimant's testimony not entirely credible, citing conservative treatment, lack of prescribed assistive devices, post-pacemaker work history, consultative exam findings, and daily activities (shopping, transit, chores).
- Smith appealed to the District Court after SSA denied review; Magistrate Judge Robinson recommended affirming the ALJ; the District Judge conducted de novo review of objections and adopted the R&R, denying Smith's motion for reversal and granting SSA's motion for affirmance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ improperly weighed treating physicians' opinions | ALJ failed to give controlling weight to treating physicians (Drs. Onyeaghala, Burris) | ALJ permissibly discounted inconsistent or legal-conclusion aspects of treating opinions and explained reasons | Court held ALJ adequately weighed opinions and provided reasons supported by record evidence |
| Whether RFC finding was supported by substantial evidence | Smith cannot perform even limited sedentary work; RFC not supported by record | RFC is supported by medical records, conservative treatment, work history, consultative exam, and activities of daily living | Court held RFC was supported by substantial evidence |
| Whether ALJ erred in discounting claimant's credibility | ALJ's adverse credibility finding lacked substantial-evidence support | ALJ provided specific, evidence-supported reasons (treatment history, activities, lack of assistive devices) | Court held credibility finding was adequately supported |
| Whether legal standards (treating physician rule / substantial evidence) were correctly applied | ALJ misapplied treating-physician rule and ignored contrary evidence | ALJ applied legal standards, explained weight assigned, and relied on substantial evidence | Court held legal standards were properly applied and decision affirmed |
Key Cases Cited
- Butler v. Barnhart, 353 F.3d 992 (D.C. Cir. 2004) (standard for reviewing ALJ and treating-physician rule)
- Rossello ex rel. Rossello v. Astrue, 529 F.3d 1181 (D.C. Cir. 2008) (definition of substantial evidence review)
- Pierce v. Underwood, 487 U.S. 552 (1988) (articulation of substantial-evidence standard)
- Warfield v. Colvin, 134 F. Supp. 3d 11 (D.D.C. 2015) (permissible rejection of internally inconsistent medical opinions)