Troy v. Colvin
266 F. Supp. 3d 288
| D.D.C. | 2017Background
- Sheila M. Troy applied for SSDI and SSI in 2011, alleging disability beginning March 18, 2010 from a pituitary tumor (surgery), diabetes, and carpal tunnel syndrome; her claims were denied administratively and by an ALJ in December 2013.
- The ALJ found Troy had multiple severe impairments but did not meet a Listing; assessed an RFC for sedentary work with additional limits on standing, sitting, lifting, and frequent hand use.
- The ALJ credited a vocational expert who testified Troy could perform past work as a computer security specialist and therefore was not disabled; the Appeals Council denied review.
- Troy sued, challenging (1) the ALJ’s credibility findings, (2) the weighing of opinion evidence (specifically a March 31, 2010 note from NP Adisa), and (3) reliance on a vocational hypothetical the plaintiff contends was incomplete.
- Magistrate Judge Robinson recommended affirmance; the district court adopted the R&R, rejecting Troy’s objections and holding the ALJ’s credibility, RFC, and Step 4 findings were supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly weighed NP Adisa’s March 31, 2010 note restricting "no strenuous activity, bending, straining, stooping" | Adisa’s instruction were permanent limitations that should have been given controlling weight | The note reflected temporary post‑operative guidance shortly after surgery and was time‑limited | ALJ reasonably treated Adisa’s note as temporary recovery instructions; substantial evidence supports time‑limited treatment |
| Whether the ALJ properly evaluated Troy’s subjective symptom statements (credibility) | ALJ improperly discounted Troy’s symptom statements and relied solely on objective medical findings | ALJ applied the two‑step regulatory framework, considered the whole record (medical opinions, exams, daily activities, hearing observations) and explained inconsistencies | Court held ALJ provided specific, legally sufficient reasons and did not reject statements based only on objective evidence |
| Whether the RFC and Step 4 findings were supported by substantial evidence | (Implicit) Plaintiff argued RFC did not capture all limitations, making the VE hypothetical incomplete | Commissioner: substantial evidence supports the RFC and VE testimony that Troy could perform past work | Plaintiff did not object to R&R on these points; court adopted R&R and affirmed RFC and Step 4 determinations |
Key Cases Cited
- Butler v. Barnhart, 353 F.3d 992 (D.C. Cir. 2004) (standard for burden and substantial‑evidence review in Social Security cases)
- Rossello ex rel. Rossello v. Astrue, 529 F.3d 1181 (D.C. Cir. 2008) (substantial‑evidence review is highly deferential)
- Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (definition of substantial evidence)
- Rutherford v. Barnhart, 399 F.3d 546 (3d Cir. 2005) (RFC must include claimant’s credibly established limitations)
- Thomas v. Arn, 474 U.S. 140 (U.S. 1985) (district court review of magistrate judge recommendations)