Yarrington v. Berryhill, 4:17-cv-00033

Plaintiff Jennifer Yarrington (born 1982) applied for DIB and SSI alleging disability from April 27, 2012, based on migraines, mental impairments, and musculoskeletal problems; applications denied at all administrative levels and ALJ decision issued Feb. 10, 2016; Appeals Council denied review.
Medical record: recurrent emergency visits for migraines through late 2013; no documented migraine treatment after Oct. 2013 in the administrative record; mental-health treatment from psychiatrist Dr. Linda Sabonya showing diagnoses of depression/bipolar disorder and anxiety with generally normal attention, judgment, and memory and improvement on medication.
Treating psychiatrist (Dr. Sabonya) completed attorney-submitted questionnaires (2015) checking boxes for marked limitations in concentration/persistence/pace and predicted >3 absences/month.
Two state agency psychologists reviewed records and found only moderate limits in detailed instructions/concentration and no significant limits for simple instructions or sustaining a normal workday.
ALJ gave little weight to Dr. Sabonya’s questionnaire (finding it inconsistent with her treatment notes), afforded significant/moderate weight to state consultants, discounted portions of claimant testimony regarding severity, and adopted a restrictive RFC (reduced to less-than-full-range sedentary work with extensive non-exertional limits). Relying on a VE, ALJ found jobs existed and denied benefits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ properly weighed treating psychiatrist's opinion	Yarrington: ALJ improperly discounted Dr. Sabonya’s opinions about marked limitations and absences; those opinions are supported by treatment notes	Commissioner: The psychiatrist’s attorney-completed checkbox forms lacked explanation and conflicted with her own treatment notes showing normal attention/judgment and stability on medication; state consultants’ opinions were consistent with records	Court: ALJ permissibly gave little weight to the questionnaire and relied on state consultants; decision supported by substantial evidence
Whether ALJ properly assessed claimant's credibility about symptom severity and functional limits	Yarrington: ALJ improperly discounted her testimony about frequent, severe migraines and mental-health effects	Commissioner: Treatment records, emergency-room notes showing symptomatic control, lack of ongoing migraine treatment after 2013, and clinician observations supported ALJ’s adverse credibility finding	Court: ALJ’s credibility determination was supported by substantial evidence and did not require remand

Mastro v. Apfel, 270 F.3d 171 (4th Cir. 2001) (scope of district court review of SSA decisions)
Hays v. Sullivan, 907 F.2d 1453 (4th Cir. 1990) (review limited to substantial evidence and proper legal standards)
Richardson v. Perales, 402 U.S. 389 (1971) (definition of substantial evidence)
Craig v. Chater, 76 F.3d 585 (4th Cir. 1996) (two-step credibility analysis for subjective symptoms)
Lewis v. Berryhill, 858 F.3d 858 (4th Cir. 2017) (treating-source rule and ALJ’s obligation to explain weight given to medical opinions)
Smith v. Schweiker, 795 F.2d 343 (4th Cir. 1986) (state consultant opinions may support denial if consistent with other evidence)
Mason v. Shalala, 994 F.2d 1058 (3d Cir. 1993) (check-box forms without explanation entitled to little weight)
Johnson v. Barnhart, 434 F.3d 650 (4th Cir. 2005) (when evidence conflicts, ALJ resolves conflicts not the court)