Stephens v. Social Security Administration, Commissioner
4:16-cv-01377
| N.D. Ala. | Jan 26, 2018Background
- Cynthia Stephens (claimant) applied for Disability Insurance Benefits alleging disability from June 13, 2012; ALJ denied benefits and Appeals Council denied review.
- Claimant is limited education, prior laborer, had prior cervical surgery and sustained workplace trauma (bull attack) injuring right knee; underwent knee and right-shoulder surgeries and physical therapy.
- ALJ found medically determinable impairments including multi-ligament knee injuries, prior shoulder labral debridement and acromial decompression, degenerative disc disease, obesity, hypertension, and right-eye vision loss.
- ALJ assessed an RFC for light work with numerous nonexertional restrictions (no lower-extremity controls, no overhead reaching/lifting, no bilateral vision/depth-perception jobs, avoid hazards and certain environmental exposures).
- ALJ discounted claimant’s subjective pain/limitation testimony based on objective records, normal/near-normal exam findings post-surgery, poor effort/exaggeration on FCEs, and claimant’s reported daily activities; relied on a VE who identified available jobs consistent with the RFC.
- Magistrate Judge affirmed the Commissioner, concluding the ALJ applied proper legal standards and substantial evidence supports the decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly evaluated claimant's subjective pain and RFC | Stephens says ALJ failed to credit her neck/arm/knee pain and walking/standing limits | Commissioner contends ALJ reasonably weighed objective evidence, poor effort on FCEs, and daily activities | Held: ALJ provided adequate reasons; substantial evidence supports discounting claimant's credibility and the RFC |
| Whether ALJ failed to consider medical evidence or substituted lay judgment | Stephens argues ALJ ignored or misapplied treating/examining evidence supporting disabling limitations | Commissioner argues ALJ considered records, gave appropriate weight to consultative exam and treating notes | Held: Court finds ALJ considered medical evidence, credited consultative exam, and decision is supported by record |
| Whether VE testimony required acceptance of hypothetical based on claimant's credible pain testimony | Stephens cites VE testimony that jobs disappear if her subjective limits are accepted | Commissioner notes VE response relied on hypotheticals ALJ found unsupported and VE cannot opine on medical credibility | Held: VE testimony based on rejected hypothetical not controlling; ALJ permissibly relied on VE answers tied to ALJ’s RFC |
| Whether ALJ accounted for obesity, age, and specific functional limits (e.g., overhead reaching) | Stephens contends ALJ ignored obesity/age and certain shoulder limits | Commissioner points to explicit consideration of age and obesity and RFC restrictions (no overhead reach, occasional other reaching) | Held: Court finds ALJ considered age and obesity and accommodated shoulder limitation in RFC |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (administrative factfinding review standard and scope of record review)
- Wilson v. Barnhart, 284 F.3d 1219 (11th Cir.) (ALJ credibility and RFC must be supported by substantial evidence)
- Bloodsworth v. Heckler, 703 F.2d 1233 (11th Cir.) (definition of substantial evidence)
- Holt v. Sullivan, 921 F.2d 1221 (11th Cir.) (two-part test for subjective pain testimony)
- Foote v. Chater, 67 F.3d 1553 (11th Cir.) (credibility findings must be clearly articulated and supported)