Youmans v. Astrue
2012 U.S. Dist. LEXIS 56687
D.D.C.2012Background
- Youmans filed disability applications in 2006 for DIB and SSI, which were denied and later upheld at a 2009 hearing.
- The ALJ found Plaintiff had COPD, chronic bronchitis, and hypertension as severe impairments and weighed multiple doctors' opinions.
- The ALJ gave great weight to Drs. Klohn and Kukla and little weight to Drs. Brown, Kassahun, and Allen, forming Plaintiff's residual functional capacity.
- The RFC limited Plaintiff to less than a full range of light work, with specific lifting, standing/walking, and environmental exposure restrictions.
- A VE testified that Plaintiff could perform about 35% of unskilled light jobs and 50% of unskilled sedentary jobs in the national economy, leading to a finding of not disabled.
- Plaintiff appealed, arguing improper environmental limitations and improper substitution of medical opinions for the RFC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether environmental limitations were adequately explained | Youmans contends the RFC should include more substantial environmental limits. | Astrue argues the ALJ adequately supported the limitation to avoid concentrated exposure based on the record and Kukla's opinion. | No reversible error; ALJ's concentration-exposure limitation supported by substantial evidence. |
| Whether the ALJ improperly substituted his own opinion for medical experts | Youmans claims the ALJ used conservative treatment as evidence for a less restrictive RFC contrary to medical opinions. | Astrue argues the ALJ weighed conflicting medical opinions and did not substitute his own medical judgment. | No error; ALJ appropriately weighed medical opinions and substantial evidence supported RFC determination. |
Key Cases Cited
- Shaw v. Apfel, 221 F.3d 126 (2d Cir. 2000) (treating-physician weight and reliance when opinions conflict)
- Jones v. Astrue, 647 F.3d 350 (D.C. Cir. 2011) (treating physician weight; explanation required for disagreements)
- Williams v. Shalala, 997 F.2d 1494 (D.C. Cir. 1993) (weight of treating physicians; substantial evidence standard)
- Turner v. Astrue, 390 Fed. Appx. 581 (7th Cir. 2010) (ALIJ credibility in weighing conflicting medical opinions)
- Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (substantial evidence standard in SSA determinations)