Uwe Taylor v. Michael Astrue, Commissioner
480 F. App'x 302
| 5th Cir. | 2012Background
- Taylor appeals SSA denial of disability benefits.
- ALJ found no disability and non-severe impairments after hearing in 2009; plaintiff was 49.
- Medical records showed largely normal MRI/EEG and unremarkable neurophysiology.
- Specialist testimony indicated no anatomical basis for pain; mental health claims deemed non-severe.
- Magistrate judge and district court affirmed the ALJ; standard of review is deferential to substantial evidence and legal standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly determined Taylor's residual functional capacity. | Taylor argues ALJ substituted medical opinion. | Commissioner contends RFC properly derived from medical evidence. | RFC properly determined; ALJ interpreted medical evidence. |
| Whether ALJ properly weighed medical evidence against Taylor’s claims. | Records do not corroborate pain allegations. | Record shows lack of corroboration and normal tests. | Substantial evidence supports non-disability finding. |
| Whether Taylor's mental health claims were properly considered. | Mental issues should have been found severe. | No evidence of functional impairment; no treatment sought. | ALJ's handling of mental health claims harmless error; no remand needed. |
| Whether any procedural error in applying Stone standard affected outcome. | ALJ failed to cite Stone v. Heckler. | Procedural perfection unnecessary when rights not affected. | Harmless error; substantial evidence supports non-severity of mental claims. |
Key Cases Cited
- Greenspan v. Shalala, 38 F.3d 236 (5th Cir. 1994) (deferential standard of review; substantial evidence rule)
- Leggett v. Chater, 67 F.3d 558 (5th Cir. 1995) (substantial evidence threshold for disability findings)
- Richardson v. Perales, 402 U.S. 389 (Supreme Court 1971) (substantial evidence standard applies to administrative findings)
- Ripley v. Chater, 67 F.3d 552 (5th Cir. 1995) (RFC determination is the ALJ's sole responsibility)
- Stone v. Heckler, 752 F.2d 1099 (5th Cir. 1985) (legal standard for severity of disability; procedural perfection not required)
- Mays v. Bowen, 837 F.2d 1362 (5th Cir. 1988) (harmless error where rights not affected)
- Hames v. Heckler, 707 F.2d 162 (5th Cir. 1983) (functionally impairing mental impairment required to preclude work)