Warfield v. SSA
3:18-cv-00022
E.D. Ky.Jul 8, 2019Background
- Plaintiff filed for disability insurance benefits (alleged onset Aug 2011) citing severe musculoskeletal problems, anxiety, depression, obesity, and fibromyalgia; application denied initially and on reconsideration.
- Administrative hearing held; Plaintiff (47) testified and a vocational expert (VE) testified; ALJ Roger Reynolds issued an unfavorable decision; Appeals Council denied review.
- ALJ found at Step 2 multiple severe impairments (lumbar spine post‑surgery, osteoarthritis, thyroiditis, anxiety/depression, obesity, fibromyalgia) but no listing‑level impairment at Step 3.
- ALJ assessed an RFC for sedentary work with numerous physical and mental restrictions (needs cane for prolonged ambulation, limited climbing, no overhead work, simple repetitive tasks, occasional changes, limited social contact).
- ALJ gave limited weight to consultative psychologist Dr. Witten’s more restrictive opinions and rejected state psychologists’ findings of no severe mental impairment in part; relied on mostly normal mental exam findings and effective medication.
- ALJ concluded jobs exist in significant numbers the claimant could perform; district court reviewed the record and affirmed, finding the ALJ’s decision supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mental‑impairment RFC | ALJ improperly discounted treating/consultative opinions and failed to account for marked limitations (stress, supervisors/coworkers) | ALJ reasonably weighed opinions; objective mental exam findings were largely normal and medications effective, so less restrictive RFC supported | Court: ALJ’s mental RFC supported by substantial evidence; limitations included in RFC were adequate and VE identified jobs |
| Use of a cane | ALJ erred by stating no prescription for cane and failed to fully account for need | Any error was harmless because inclusion of cane would not change VE’s job numbers; substantial jobs remain | Court: Error harmless; even with continuous cane use substantial jobs (approx. 325,490) exist |
| Substantial‑evidence review of ALJ factfinding | N/A (procedural) | N/A | Court: Must defer to ALJ if record contains substantial evidence; here standard met — no reversible error |
Key Cases Cited
- Garner v. Heckler, 745 F.2d 383 (6th Cir. 1984) (defines "substantial evidence" standard and scope of review)
- Kirk v. Secretary of Health and Human Services, 667 F.2d 524 (6th Cir. 1981) (reviewing court must affirm if Commissioner’s decision is supported by substantial evidence)
- Bradley v. Secretary of Health and Human Services, 862 F.2d 1224 (6th Cir. 1988) (court may not reweigh evidence or decide credibility anew)
- Key v. Callahan, 109 F.3d 270 (6th Cir. 1997) (deference to ALJ even if substantial evidence could support opposite conclusion)
- Wilson v. Commissioner of Social Security, 378 F.3d 541 (6th Cir. 2004) (ALJ must build an accurate and logical bridge between evidence and RFC conclusion)
- Fisher v. Bowen, 869 F.2d 1055 (7th Cir. 1989) (harmless‑error principle; remand not required when error would not affect outcome)