Taulton v. Colvin
5:13-cv-00859
W.D. Okla.Aug 25, 2014Background
- Plaintiff Mari S. Taughton applied for Title II and Title XVI benefits; onset date claimed April 1, 2011.
- ALJ found Plaintiff capable of medium work and not disabled, based on RFC and past work as a packer.
- ALJ’s decision issued March 15, 2013; Appeals Council denied review, making the ALJ’s decision final.
- Plaintiff sought judicial review under 42 U.S.C. § 405(g) in the Western District of Oklahoma.
- Magistrate Judge recommends reversing and remanding for further proceedings; issues focus on RFC and past work evaluation.
- Key medical opinions (Dr. Gibson and Dr. Kindling) and machine-operating demands raise questions about the medium-work RFC and past work findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ adequately evaluate past relevant work demands? | Taulton argues the ALJ did not determine the physical/mental demands of her past work. | Taulton contends the VE testimony was relied on without proper ALJ findings on job demands. | Error: ALJ failed to find past work demands; remand warranted. |
| Did the ALJ properly weigh medical opinions conflicting with medium work? | Gibson/Kindling opinions limiting to light work were not adequately considered. | ALJ considered but did not adequately explain rejection of those opinions. | Error: rejection of conflicting opinions requires remand. |
| Did the RFC account for limitations like avoiding machinery and heavy lifting? | RFC allowing medium work with machinery avoidance is inconsistent with other evidence | RFC relied on some consultants; ALJ given rationale but insufficient analysis. | Inconsistent RFC findings require remand. |
| Should the case be remanded under sentence four or sentence six due to new disability finding after the ALJ decision? | New disability determination may warrant remand under sentence six for new evidence. | The proximity of subsequent favorable decision alone is not enough without new material evidence. | Court indicates remand is warranted under sentence four; consideration of sentence six also suggested. |
Key Cases Cited
- Wilson v. Astrue, 602 F.3d 1136 (10th Cir. 2010) (substantial evidence standard in 10th Cir.)
- Doyal v. Barnhart, 331 F.3d 758 (10th Cir. 2003) (legal standards for SSA review)
- Winfrey v. Chater, 92 F.3d 1017 (10th Cir. 1996) (requirement to evaluate demands of past work)
- Bowman v. Astrue, 511 F.3d 1270 (10th Cir. 2008) (three-phase analysis at step four; RFC framing)
- Wall v. Astrue, 561 F.3d 1048 (10th Cir. 2009) (reviewing the record as a whole for substantial evidence)