Collier v. Commissioner of Social Security

Background

Clay B. Collier sought review under 42 U.S.C. § 405(g) of the Commissioner’s decision denying his applications for Social Security Disability Insurance and Supplemental Security Income benefits. The administrative law judge (ALJ) found that Collier had severe impairments including polysubstance dependence, depression, anxiety, post-traumatic stress disorder, and psychotic disorder.

The ALJ found that Collier’s impairments met several listed-disorder criteria while he was using substances. The ALJ then evaluated Collier’s condition without substance use and concluded that his remaining impairments would not meet or medically equal a listed impairment. The ALJ found that, without substance use, Collier would have the residual functional capacity to perform medium work with restrictions to simple, routine tasks, simple work-related decisions, frequent interaction with supervisors, coworkers, and the public, moderate noise, and no exposure to unprotected heights or moving mechanical parts. The ALJ concluded that Collier could perform jobs existing in significant numbers in the national economy.

Issues and analysis

Collier argued that the ALJ improperly evaluated the medical opinions, determined that drug and alcohol use was material to the disability decision, assessed his credibility, found that his impairments did not meet a listing without substance use, determined his residual functional capacity, and failed to obtain vocational-expert testimony.

The court focused first on the medical opinions. It held that the ALJ gave specific and legitimate reasons, supported by substantial evidence, for assigning limited weight to treating physician Aislinn Bird’s opinion. The court relied on evidence that Collier’s symptoms and functioning improved during periods of sobriety and medication compliance, and that aspects of Dr. Bird’s assessment were inconsistent with her treatment notes. The court also upheld the ALJ’s decision to assign limited weight to examining psychologist Lorraine Schnurr’s opinion because the opinion was internally inconsistent and was not fully consistent with the examination findings and the other record evidence.

The court upheld the substantial weight given to the testimony of non-examining medical expert Julian Kivowitz, M.D. The court found substantial evidence supporting the conclusion that Collier’s symptoms decreased during periods of sobriety and medication compliance. The court also found no error in the ALJ’s treatment of the opinions from Joni K. Teague, a licensed clinical social worker, and Alexandra Miley, a marriage and family therapy trainee. The ALJ gave those opinions limited weight because they were conclusory, equivocal, based on limited treatment relationships, or did not adequately account for Collier’s substance use.

Substance-use analysis

The court explained that when drug or alcohol use occurs alongside an alleged disability, the issue is whether the claimant would still be disabled if he stopped using drugs or alcohol. The claimant bears the burden of showing that substance use is not a contributing factor material to the disability determination.

The court concluded that the ALJ properly considered evidence of Collier’s functioning during periods of sobriety, including improved symptoms, largely unremarkable mental-status examinations, and evidence of medication compliance. Although reasonable minds could disagree about whether Collier’s mental disorders would improve enough to prevent disability without substance use, the court held that the ALJ’s interpretation was supported by substantial evidence and was legally adequate.

Because the court found no error in the substance-use analysis, it also found no error in the ALJ’s assessment of Collier’s statements about his symptoms. The court further rejected Collier’s remaining arguments concerning the listings, residual functional capacity, and vocational-expert testimony because those arguments rested on challenges the court had already rejected concerning the medical evidence and substance-use analysis.

Disposition

Judge Donna Ryu granted the Commissioner’s motion for summary judgment and denied Collier’s motion for summary judgment. The court therefore upheld the administrative decision denying Collier’s disability benefits.