Stallings v. Social Security Administration
2:16-cv-02208
D. Kan.Apr 7, 2017Background
- Plaintiff LaVita A. Stallings applied for Disability Insurance Benefits alleging disability beginning June 1, 2012; ALJ denied benefits and the denial was appealed to district court.
- Medical history focused on longstanding bilateral knee osteoarthritis, injections, conservative care, and a later left total knee replacement; some post-op physical therapy notes showed limited knee extension but also documented functional gains.
- Consultative examiner Dr. White performed a one-time exam (stated he reviewed records) and found no exertional limitations; ALJ nonetheless adopted a restricted RFC (limited range of light work with postural limits).
- Plaintiff testified to substantial knee pain, use of a cane, and missing work; ALJ found her allegations only partially credible, citing objective exam findings, successful surgery, minimal need for assistive device, and possible secondary-gain behavior.
- District court reviewed whether the ALJ’s RFC, reliance on Dr. White, and credibility findings were legally and factually supported, and ultimately affirmed the Commissioner’s decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RFC is supported by record | Stallings: knee disease and post-op deficits preclude standing/walking required for light work; PT notes and testimony show greater limits | Commissioner: objective exams, minimal treatment, functional findings, and post-op improvement support ALJ’s RFC | Affirmed — substantial evidence supports ALJ’s RFC determination |
| Weight given to consultative exam (Dr. White) | Dr. White’s one-time exam missed later knee replacement and so should not be heavily relied upon | Commissioner: Dr. White reviewed records; ALJ gave his opinion great weight but still limited RFC in claimant’s favor | Affirmed — ALJ reasonably evaluated and tempered Dr. White’s opinion |
| Credibility of subjective symptom allegations | Stallings: ALJ mischaracterized testimony, ignored work history and reasons for gaps in treatment, and was inconsistent | Commissioner: ALJ’s credibility finding is entitled to deference and supported by multiple valid reasons; any minor error harmless | Affirmed — credibility finding supported by substantial evidence and not reversible |
| Consideration of all record evidence | Stallings: ALJ failed to consider or discuss some relevant medical/PT notes and lay evidence | Commissioner: ALJ adequately summarized and considered the record; need not cite every document | Affirmed — ALJ sufficiently considered the record; no omitted material evidence shown |
Key Cases Cited
- Wall v. Astrue, 561 F.3d 1048 (10th Cir.) (standard for substantial evidence review)
- Lax v. Astrue, 489 F.3d 1080 (10th Cir.) (agency conclusions entitled to deference when supported by substantial evidence)
- Richardson v. Perales, 402 U.S. 389 (Sup. Ct.) (definition of substantial evidence)
- Wilson v. Astrue, 602 F.3d 1136 (10th Cir.) (credibility findings must be closely and affirmatively linked to substantial evidence)
- Chapo v. Astrue, 682 F.3d 1285 (10th Cir.) (ALJ may temper medical opinions in claimant’s favor)
- Kepler v. Chater, 68 F.3d 387 (10th Cir.) (list of factors for evaluating symptom testimony)
- Nguyen v. Shalala, 43 F.3d 1400 (10th Cir.) (court reviews the ALJ’s final decision, not under new rules issued after decision)
- Bowman v. Astrue, 511 F.3d 1270 (10th Cir.) (court may not reweigh evidence on appeal)