Willis v. Social Security Administration
1:16-cv-00784
W.D. La.Aug 28, 2017Background
- Elisha Dena Willis applied for DIB, Medicare, and SSI alleging disability from cervical spine disorders, migraines, and lumbar degenerative disease; SSA denied benefits and an ALJ held a hearing on May 1, 2014.
- Medical history includes two anterior cervical discectomy and fusion procedures (2010 and December 2012), ongoing cervical radiculopathy, occipital neuralgia/migraines, multiple pain treatments (injections, nerve blocks, medications, TENS), and continued complaints of neck, arm, and headache pain.
- Treating and consultative records show mixed findings: objective imaging and surgeries with some post-op improvement, normal motor strength and, at times, full cervical range of motion; persistent subjective pain, medication use, and functional complaints (limited sitting, lifting ~15 lbs, headaches causing multi-day exacerbations).
- Work history: past relevant sedentary clerical/administrative work; an unsuccessful work attempt (Dec 2011–Mar 2012) in light customer-service work; vocational expert testified that with certain non-dominant hand limitations alternate sedentary jobs existed.
- The ALJ found Willis had severe impairments but retained the residual functional capacity (RFC) for sedentary work with only occasional climbing, stooping, kneeling, crouching, crawling, and occasional bilateral overhead reaching; concluded Willis could perform past relevant work and was not disabled as of the decision.
- Magistrate recommended denying Willis’s appeal, finding (1) the ALJ reasonably evaluated credibility and RFC based on the record and (2) the unsuccessful light-work attempt did not preclude sedentary work capacity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of RFC evaluation | Willis: ALJ failed to credit her pain, migraines, medication side effects, and other non-ROM evidence when formulating RFC | Commissioner: ALJ properly weighed objective findings, treatment response, medication records, and inconsistencies in testimony | ALJ did not err; substantial evidence supports RFC and credibility findings |
| Weight given to work attempt | Willis: ALJ ignored that her unsuccessful 2011–2012 work attempt demonstrates inability to sustain any work | Commissioner: That attempt involved light work; ALJ restricted RFC to sedentary work, so unsuccessful light-work attempt is not dispositive | ALJ permissibly concluded the unsuccessful light-work attempt does not preclude sedentary work |
| Credibility determination standards | Willis: ALJ failed to consider all relevant symptom evidence and side effects | Commissioner: ALJ applied required factors (objective evidence, treatment efficacy, daily activities, inconsistencies) and explained reasons for discounting severity | Court: ALJ made required affirmative findings, articulated reasons, and credibility determination is supported by substantial evidence |
| Step 4 conclusion (past relevant work) | Willis: Given limitations and migraines, she cannot perform past administrative assistant work | Commissioner: RFC and VE testimony show she can perform her past sedentary/administrative work or alternate sedentary positions | Held: ALJ reasonably relied on VE and RFC to find Willis can perform past relevant work; not disabled |
Key Cases Cited
- Greenspan v. Shalala, 38 F.3d 232 (5th Cir. 1994) (explains sequential evaluation and burden shift at step five)
- Chambliss v. Massanari, 269 F.3d 520 (5th Cir. 2001) (objective evidence requirement for pain complaints)
- Falco v. Shalala, 27 F.3d 160 (5th Cir. 1994) (ALJ must articulate reasons for rejecting subjective complaints)
- Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (standard for substantial evidence review of administrative findings)
- Elzy v. Railroad Retirement Bd., 782 F.2d 1223 (5th Cir. 1986) (credibility findings fall within ALJ’s province)
- Carry v. Heckler, 750 F.2d 479 (5th Cir. 1985) (upholding ALJ credibility and RFC conclusions)