Young v. Astrue
3:12-cv-01712
M.D. Penn.Feb 11, 2014Background
- Plaintiff Lori L. Young challenged a Social Security disability denial under Title II after onset date of November 20, 2009.
- Young, born December 20, 1958, had a high school education and worked as a part-time personal caregiver prior to filing; previously employed as a dental office receptionist.
- Alleged impairments included Bipolar Disorder, Type II Diabetes, Hypertension, Chronic Fatigue, and Fibromyalgia.
- ALJ Daniel Meyers concluded Young was not disabled and found RFC to perform less than the full range of light work with unskilled requirements and 85% attention/concentration, plus limited workplace changes.
- The ALJ determined there were jobs in the national economy suitable for Young given age, education, work experience, and RFC, relying on a vocational expert.
- Young challenged the RFC assessment for chronic fatigue and concentration, and the weight afforded to treating psychiatrist Dr. Potluri versus the State agency reviewer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the RFC properly accounts for chronic fatigue. | Young contends chronic fatigue was not adequately considered. | Defendant argues RFC accounted for physical impairments, and chronic fatigue evidence supported by record. | Affirmed; RFC supported by substantial evidence including chronic fatigue considerations. |
| Whether the 85% concentration finding is supported by substantial evidence. | Young argues concentration limit is not substantiated. | ALJ conducted exhaustive review and found 85% concentration consistent with record. | Affirmed; substantial evidence supports 85% concentration limitation. |
| Whether the ALJ properly weighed treating physician Dr. Potluri against the State agency reviewer. | ALJ should give greater weight to treating psychiatrist; erred by giving great weight to the State reviewer. | ALJ appropriately limited Potluri's weight due to inconsistency with objective evidence and accorded great weight to the State reviewer. | Affirmed; ALJ properly weighed opinions and relied on substantial evidence. |
Key Cases Cited
- Morales v. Apfel, 225 F.3d 310 (3d Cir. 2000) (treating physician weight and analysis of disability opinions)
- Hartranft v. Apfel, 181 F.3d 358 (3d Cir. 1999) (substantial evidence standard and credibility considerations)
- Cotter v. Harris, 642 F.2d 700 (3d Cir. 1981) (requirement to articulate evidence accepted or rejected by the ALJ)
- Smith v. Califano, 637 F.2d 968 (3d Cir. 1981) (scope of administrative review and substantial evidence)
- Brown v. Bowen, 845 F.2d 1211 (3d Cir. 1988) (definition and application of substantial evidence)
- Fargnoli v. Massanari, 247 F.3d 34 (3d Cir. 2001) (SUBSTANTIAL evidence standard and deferential review)
- Mason v. Shalala, 994 F.2d 1058 (3d Cir. 1993) (evaluation of medical evidence in disability determinations)
- Mastro v. Apfel, 270 F.3d 171 (4th Cir. 2001) (weight given to medical opinions and credibility)