Workman, II v. Commissioner of Social Security
1:20-cv-00184
N.D. OhioMar 25, 2021Background
- On September 20, 2017, Fred T. Workman II applied for disability insurance benefits and SSI alleging heart disease, hypertension, dyspnea, and knee problems.
- The SSA denied benefits initially and on reconsideration; an ALJ held a hearing on July 3, 2019, and on July 23, 2019 denied Workman’s claims. The Appeals Council declined review.
- Workman filed suit in district court seeking review; he argued the ALJ improperly weighed medical-opinion evidence (Dr. Newton) and misapplied the legal standard for assessing subjective symptoms.
- Magistrate Judge Parker issued a Report & Recommendation finding the ALJ applied proper legal standards and that substantial evidence supported the decision to discount Dr. Newton’s opinion and Workman’s symptom statements.
- Workman objected; the district court reviewed the objections de novo, overruled them, adopted the R&R, and affirmed the Commissioner’s final decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly evaluated medical-opinion evidence (Dr. Newton) | Workman: ALJ failed to properly weigh/credit Dr. Newton’s opinion | Commissioner: ALJ followed SSA regs, considered supportability & consistency, and reasonably found Dr. Newton unpersuasive | Court: ALJ applied correct standard; substantial evidence supports discounting Dr. Newton’s opinion |
| Whether the ALJ properly evaluated Workman’s subjective symptom claims | Workman: ALJ applied wrong standard / failed to credit intensity and persistence of symptoms | Commissioner: ALJ considered the full record (objective evidence, activities, cardiac rehab, walking) and permissibly discounted symptom severity | Court: ALJ used proper standard; substantial evidence supports discounting Workman’s symptom statements |
Key Cases Cited
- Bowen v. Comm’r of Soc. Sec., 478 F.3d 742 (6th Cir. 2007) (review standard: affirm if supported by substantial evidence and correct legal criteria)
- Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (substantial-evidence standard and deference even when record might support opposite conclusion)
- Warner v. Comm’r of Soc. Sec., 375 F.3d 387 (6th Cir. 2004) (definition and application of substantial-evidence review)
- Mullen v. Bowen, 800 F.2d 535 (6th Cir. 1986) (‘‘zone of choice’’ language describing courts’ limited role under substantial-evidence review)
- Poe v. Comm’r of Soc. Sec., [citation="342 F. App'x 149"] (6th Cir. 2009) (ALJ not required to recite a physician’s opinion verbatim in the RFC finding)