Yarborough v. Commissioner of Social Security Administration
6:16-cv-03278
D.S.C.Dec 11, 2017Background
- Plaintiff Donald Craig Yarborough applied for DIB and SSI, alleging disability beginning Feb 1, 2012; applications filed July 12, 2012 and denied administratively.
- ALJ held a hearing Nov 13, 2014, issued an unfavorable decision Jan 14, 2015; Appeals Council denied review, prompting this district-court appeal.
- Magistrate Judge issued a Report recommending the ALJ’s denial be affirmed; Plaintiff filed three specific objections to that Report.
- Central medical issues raised: (1) whether the ALJ improperly omitted a pre-onset (Apr 2011) MRI and certain range-of-motion observations when formulating the RFC; (2) whether the ALJ improperly discounted treating physician Dr. Philip Rhine’s opinions; (3) whether the ALJ’s credibility assessment of Plaintiff was supported by substantial evidence.
- The district court reviewed the Report de novo as to Plaintiff’s specific objections, concluded the Magistrate Judge’s analysis was well-reasoned, overruled the objections, adopted the Report, and affirmed the Commissioner’s denial of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility/weight of Apr 2011 MRI and ROM evidence in RFC | MRI and reduced ROM should have been considered; MRI is more detailed and not negated by time gap | MRI predates alleged onset (~10 months); x-rays in the relevant period showed same condition (spondylopathy); ALJ acknowledged spondylopathy | Court: MRI was outside relevant period and ALJ’s reliance on contemporaneous x-rays and findings was reasonable; RFC supported by substantial evidence |
| Weight afforded to treating physician Dr. Rhine’s opinions | ALJ erred in giving Dr. Rhine’s opinions little weight; pain control and medication management were improperly considered | ALJ found Rhine’s lifting restrictions unsupported by overall record; management of medication and objective findings undercut opinion reliability | Court: Magistrate correctly found ALJ permissibly discounted Rhine’s opinions where unsupported by record; objection overruled |
| Credibility evaluation of claimant | ALJ’s credibility determination was ambiguous and insufficiently explained | ALJ’s credibility findings were supported by record; Magistrate addressed Plaintiff’s arguments and found substantial evidence supported the ALJ | Court: Agreed with Magistrate that credibility assessment was supported by substantial evidence; objection overruled |
| Standard of review / scope of remand | (implicit) ALJ errors warrant reversal or remand | (implicit) ALJ’s decision falls within the zone of choice; district court should not reweigh evidence | Court: Applied substantial-evidence/deferential review; affirmed ALJ’s decision without reweighing evidence |
Key Cases Cited
- Mathews v. Weber, 423 U.S. 261 (U.S. 1976) (magistrate judge’s report is advisory; district court must make final determination)
- Orpiano v. Johnson, 687 F.2d 44 (4th Cir. 1982) (general, conclusory objections do not require de novo review)
- Pass v. Chater, 65 F.3d 1200 (4th Cir. 1995) (claimant bears burden to produce evidence and prove disability)
- Hays v. Sullivan, 907 F.2d 1453 (4th Cir. 1990) (ALJ— not the court—resolves conflicts in the evidence)
- Steurer v. Bowen, 815 F.2d 1249 (8th Cir. 1987) (court must view the entire record under the substantial-evidence standard)
- Clarke v. Bowen, 843 F.2d 271 (8th Cir. 1988) (administrative decisions are within a zone of choice and not reversible merely because substantial evidence might support an opposite outcome)
- Johnson v. Barnhart, 434 F.3d 650 (4th Cir. 2005) (court must not reweigh conflicting evidence or substitute its judgment for the ALJ)
- Smith v. Chater, 99 F.3d 635 (4th Cir. 1996) (court must sustain an ALJ’s decision if it is supported by substantial evidence)