Willis v. Commissioner of Social Security, 4:16-cv-00677

Plaintiff Ramona Machelle Willis (born 1960) applied for Title II DIB, alleging disability beginning June 9, 2013, due to multiple physical and mental impairments (knee revisions, cervical and lumbar spine disease, fibromyalgia, Sjogren’s, depression, coronary disease, obesity).
Administrative denials were followed by an ALJ hearing (Jan. 5, 2016) with testimony from Plaintiff and a vocational expert; the ALJ issued an adverse decision on March 2, 2016; Appeals Council denied review.
Relevant medical evidence included multiple knee revision surgeries, prior cervical fusion, imaging showing degenerative and stenotic spinal disease, diagnoses of fibromyalgia and Sjogren’s, and treating physician opinions restricting work capacity (notably Dr. McColm’s very restrictive RFC).
State agency consultants provided less restrictive physical and mental assessments (e.g., light work with limited standing/walking and ability to follow detailed but not complex instructions).
The ALJ found Plaintiff could perform a reduced range of light work (20/10 lb lift pattern, 2 hours standing/walking, 6 hours sitting, frequent handling, work in 2-hour intervals between breaks, limited to detailed but not complex tasks) and could return to her past sedentary/semi-skilled mortgage loan officer work; therefore not disabled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ failed to fully develop the record by not ordering consultative exams (pain specialist, mini-work eval, or follow-up with treating doctors)	ALJ hinted further testing was useful but did not obtain it; additional exams would have filled ‘‘holes’’ in the record and supported treating opinions	ALJ’s statements were not a determination that the record was inadequate; ordering consultative exams is discretionary and unnecessary where substantial evidence exists; plaintiff didn’t show prejudice	Court: No failure to develop the record — ALJ had sufficient evidence and plaintiff failed to show a consultative exam would have produced a different result
Whether the ALJ gave proper weight to treating physicians’ opinions (Drs. McColm, Mollabashy, You-Surles)	The ALJ declined to give controlling weight without adequate § 404.1527(c) analysis or good cause	ALJ provided reasons: opinions were brief/conclusory, not well supported by objective findings or consistent with record; ALJ considered the § 404.1527(c) factors	Court: ALJ gave specific, legitimate reasons (good cause) and adequately applied the required factors; discounting treating opinions was proper

Greenspan v. Shalala, 38 F.3d 232 (5th Cir. 1994) (standard of review and substantial-evidence review for SSA decisions)
Audler v. Astrue, 501 F.3d 446 (5th Cir. 2007) (burden of proof framework in sequential evaluation)
Ripley v. Chater, 67 F.3d 552 (5th Cir. 1995) (ALJ’s duty to fully and fairly develop the record)
Kane v. Heckler, 731 F.2d 1216 (5th Cir. 1984) (requiring claimant to show prejudice from a failure to develop the record)
Newton v. Apfel, 209 F.3d 448 (5th Cir. 2000) (treating physician rule; when to afford controlling weight and need to consider § 404.1527(c) factors)
Turner v. Califano, 563 F.2d 669 (5th Cir. 1977) (consultative examinations not required unless necessary to make a disability determination)
Cook v. Heckler, 750 F.2d 391 (5th Cir. 1985) (definition of substantial evidence)
Bowling v. Shalala, 36 F.3d 431 (5th Cir. 1995) (courts must not reweigh evidence; ALJ credibility and evidence conflicts are for ALJ to resolve)