Sutton v. Commissioner of Social Security
1:23-cv-01392
E.D.N.YJun 6, 2024Background
- Romeo Sutton applied for Social Security disability insurance benefits, claiming disability due to a left shoulder injury, sleep apnea, and spinal disease.
- Sutton’s work history includes 20 years as a sanitation worker, with his claimed disability onset date in May 2018.
- Medical evidence included treatment by his primary care physicians and evaluations by consultative examiners and state agency consultants.
- The ALJ found that Sutton had the residual functional capacity (RFC) for light work, based on the entire record, and did not give controlling weight to his treating physician's severe restrictions.
- Sutton challenged the ALJ’s decision in federal court, arguing that the ALJ erred by not crediting his treating physician’s opinion and by relying on other, less specific medical opinions.
- The District Court reviewed the decision under the substantial evidence standard, applying regulations in effect after March 27, 2017, which do not give special deference to treating physician opinions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ's RFC determination | ALJ should have adopted stricter restrictions per treating physician | ALJ correctly weighed all opinions in light of entire record | ALJ's RFC finding supported by substantial evidence; no error |
| Weight to treating physician | Treating physician's opinion should be controlling | Treating physician rule repealed; opinion only somewhat persuasive | ALJ properly did not afford controlling weight to treating physician |
| Reliance on consultative examiner | Consultative opinion too vague to be probative | Examiner’s findings consistent with other record evidence | ALJ permissibly relied on consultative examiner's opinion |
| Substantial evidence | ALJ mischaracterized or ignored supporting evidence | ALJ's decision is amply supported by evidence | Substantial evidence supports ALJ; decision must be affirmed |
Key Cases Cited
- Schillo v. Kijakazi, 31 F.4th 64 (2d Cir. 2022) (describes Social Security disability five-step analysis and substantial evidence standard)
- Colgan v. Kijakazi, 22 F.4th 353 (2d Cir. 2022) (explains substantial evidence standard for district court review)
- Estrella v. Berryhill, 925 F.3d 90 (2d Cir. 2019) (explains ALJ’s duty to articulate crucial factors for review)