Williams v. Berryhill
268 F. Supp. 3d 46
D.D.C.2017Background
- Kyla Williams applied for Supplemental Security Income (SSI) in 2012, alleging knee pain and bipolar disorder; SSA denied benefits and an ALJ upheld the denial after a hearing.
- The ALJ found severe impairments (degenerative joint disease, obesity, bipolar disorder) but concluded Williams retained a limited sedentary residual functional capacity (RFC) allowing work with restrictions (no public contact, simple routine tasks, limited balancing/stooping, avoid hazards).
- Williams submitted functional assessments from three psychiatrists (Drs. Prayaga, Rehman, and Panbehi) stating she could not work (or would be off-task/miss work frequently).
- The treatment/psychiatric progress notes (Aug 2013–Aug 2014) were repetitive and generally reflected stability (patient reported feeling better, normal sleep, logical thought process; earlier checkbox forms noted "impaired" cognition).
- The ALJ gave the treating psychiatrists’ opinions little weight, citing inconsistencies with the treatment notes, state-agency consultants’ assessments, Williams’s daily activities, and documented noncompliance with medical advice.
- Magistrate Judge Robinson recommended affirmance; the District Court reviewed de novo, agreed that the ALJ’s weighing was supported by substantial evidence, adopted the R&R, denied Williams’s motion for reversal, and granted the Commissioner’s motion for affirmance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ improperly discounted treating psychiatrists’ opinions | Williams argued the ALJ improperly discounted treating opinions based on sparse/repetitive treatment notes and relied on an impermissible corroboration rule (citing Herrmann) | Commissioner argued the ALJ permissibly found the treating opinions inconsistent with treatment notes, state consultants, and daily activities and therefore need not give them controlling weight | Court held the ALJ permissibly discounted the opinions because substantial contradictory evidence existed and the ALJ adequately explained the reasons |
| Whether the ALJ failed to give controlling weight to treating physicians under the treating-physician rule | Williams argued the ALJ should have given controlling weight absent substantial contradictory evidence | Commissioner identified substantial contradictory evidence (treatment notes, state consultants, activities, noncompliance) justifying non-controlling weight | Court held substantial evidence supported the ALJ’s decision not to give controlling weight |
| Whether out-of-circuit precedent (Herrmann) requires reversal | Williams urged adoption of Herrmann’s critique of discounting treating opinions for sparse notes | Commissioner and court distinguished Herrmann because here the ALJ identified inconsistencies rather than requiring corroboration | Court held Herrmann inapposite; ALJ relied on inconsistencies and other evidence |
| Whether the ALJ’s explanation met the required ‘good reasons’ standard | Williams argued the ALJ’s explanations were inadequate or overly reliant on one doctor’s sparse notes | Commissioner argued the ALJ cited multiple contrary sources and explained weight given | Court held the ALJ provided sufficient explanation and cited contradictory evidence, satisfying the legal standard |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (substantial-evidence standard for administrative findings)
- Rossello ex rel. Rossello v. Astrue, 529 F.3d 1181 (highly deferential review of ALJ decisions)
- Butler v. Barnhart, 353 F.3d 992 (treating-physician rule requires explanation if opinion rejected)
- Jones v. Astrue, 647 F.3d 350 (ALJ must note contradictory evidence when rejecting treating source opinion)
- Herrmann v. Colvin, 772 F.3d 1110 (7th Cir.: critique of discounting treating opinions for lack of corroborative notes)