Lottie E. v. Berryhill
- Katherine Menendez
- 0:18-cv-00039
- U.S. District Court · District of Minnesota
- 2
In Lottie E. v. Berryhill, Judge Menendez denied Lottie E.’s summary-judgment motion and granted Berryhill’s.
Lottie E. and Nancy Berryhill. The court denied Lottie E.’s motion for summary judgment and granted Nancy Berryhill’s motion.
What happened
Lottie E. v. Berryhill involved review of an administrative law judge’s decision under the Social Security Act. Lottie E. argued that the administrative law judge should have given controlling weight to opinions from Dr. Payne and Dr. Miller.
Those doctors recommended substantial limits on sitting and standing that, according to Lottie E., would have required a finding that she was disabled. The court rejected the argument because the doctors’ opinions conflicted with their own notes, the overall record, the objective medical evidence, and Lottie E.’s reported daily activities.
Judge Katherine Menendez denied Lottie E.’s motion for summary judgment and granted Nancy Berryhill’s motion for summary judgment. The court ordered judgment to be entered accordingly.
The detailed version
- Lottie E. v. Berryhill · No. 0:18-cv-00039
- Katherine Menendez
- Mar. 6, 2019
Background
The court considered Lottie E.’s motion for summary judgment and Nancy Berryhill’s motion for summary judgment. The court heard oral argument on February 26, 2019, ruled from the bench, and issued this order to briefly restate its reasoning.
The case concerned review of an administrative law judge’s determination under the Social Security Act. The court explained that it reviews whether the administrative law judge followed the law and whether the decision was supported by substantial evidence—that is, relevant evidence that a reasonable person would accept as adequate.
Arguments and Analysis
Lottie E. argued that the administrative law judge erred by failing to give controlling weight to opinions from two treating-source doctors, Dr. Payne and Dr. Miller. Both doctors recommended substantial sitting and standing limitations. Lottie E. argued that those limitations would have required a finding that she was disabled under the Social Security Act.
The court rejected that argument for four stated reasons:
- Neither treating-source opinion was consistent with the doctor’s own notes.
- Dr. Payne’s and Dr. Miller’s findings were inconsistent with the overall record.
- Their findings relied heavily on Lottie E.’s subjective complaints, which the administrative law judge found inconsistent with the objective medical evidence.
- Lottie E.’s reports of her daily activities did not support the doctors’ conclusions.
Ruling
Judge Katherine Menendez ordered that:
- Lottie E.’s motion for summary judgment was denied. - Nancy Berryhill’s motion for summary judgment was granted.
The court also ordered that judgment be entered accordingly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.