Williams v. Commissioner of the Social Security Administration
5:14-cv-01664
D.S.C.Jun 30, 2015Background
- Plaintiff Williams applied for DIB and SSI on January 18, 2012, alleging disability onset on November 4, 2011.
- Initial and reconsideration denials preceded a November 7, 2013 hearing before an ALJ, with an unfavorable December 3, 2013 decision.
- The Appeals Council denied review, rendering the ALJ’s decision final and subject to judicial review under 42 U.S.C. § 405(g).
- Plaintiff, born October 1, 1976, alleged spinal impairment, depression, anxiety/panic disorder, and seizures; prior work included Boeing aircraft painting.
- The ALJ found Plaintiff's impairments severe (degenerative disc disease and anxiety) but concluded no disability at Step 3 and that jobs existed in the national economy; remand was recommended to address Listing 1.04 and Dr. Dawson’s opinion.
- Extensive MRI and multiple treating and consulting physicians documented spinal abnormalities, radiculopathy, and degenerative changes, with conflicting interpretations regarding Listing 1.04.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred by evaluating impairment combination at Steps 3-4 | ALJ ignored April 2011 MRI showing spine disease supporting Listing 1.04. | ALJ considered combined impairments and properly applied listings and RFC framework. | Remand warranted for proper combination-analysis and Listing 1.04 consideration. |
| Whether Plaintiff meets or equals Listing 1.04 (spine disorder) | Evidence (April 2011 MRI and other records) supports nerve root compression and other 1.04 criteria. | MRI did not show significant herniation/nerve impingement; 1.04 not met or equaled. | Not supported; remand required to reassess Listing 1.04 evidence and criteria. |
| Whether ALJ properly assessed combined impairments with Listing 12.04 (mental impairments) | Impairments in combination may meet/equal Listing 12.04; ALJ failed to address together with 1.04. | ALJ evaluated 12.04 criteria and found no equal or met listing. | Remand allows reanalysis of combined effects including Listing 12.04 with physical impairments. |
| Whether ALJ properly evaluated Plaintiff's credibility | ALJ erred in discounting subjective complaints despite documented symptoms and treatment. | ALJ followed SSR 96-7p, weighing objective findings against subjective reports. | Credibility assessment may be revisited on remand in light of reanalysis of listings. |
| Whether ALJ properly weighed Dr. Dawson’s treating-physician opinion | Dr. Dawson’s Medical Source Statement supported greater limitations and work-absence risk. | ALJ appropriately gave little weight to Dr. Dawson given lack of corroborating findings and greater weight to other physicians. | On remand, weight of Dr. Dawson’s opinion must be reconsidered in light of listing-analysis and overall record. |
Key Cases Cited
- Cook v. Heckler, 783 F.2d 1168 (4th Cir. 1986) (requirement to explain why listing analysis is not met)
- Craig v. Chater, 76 F.3d 585 (4th Cir. 1996) (treating-opinion weight and credibility assessment framework)
- Walls v. Barnhart, 296 F.3d 287 (4th Cir. 2002) (burden-shifting and use of vocational expert to show alternative work)