Jay Collier v. Nancy A. Berryhill

Background

Jay Collier sought judicial review under Section 205(g) of the Social Security Act of the Commissioner’s denial of his application for Disability Insurance Benefits. He alleged that he became unable to work because of tinnitus, peripheral neuropathy, high blood pressure, borderline diabetes, back pain, carpal tunnel syndrome, and other conditions. His alleged onset date was amended to February 9, 2013, and his last insured date was December 31, 2014.

Administrative Law Judge Robert Gonzales found that Collier had twelve severe impairments, including tinnitus, carpal tunnel syndrome, diabetes, peripheral neuropathy, lumbar degenerative disc disease, obesity, gout, hypertension, and other conditions. The judge found that Collier did not meet or medically equal a listed impairment. The judge determined that Collier could perform sedentary work with restrictions involving noise, heights, ladders, kneeling, crawling, handling, fingering, balancing, stairs, stooping, and uneven terrain. Although Collier could not perform his past work, the judge found, based on vocational-expert testimony, that other jobs existed in significant numbers that he could perform.

The Social Security Administration Appeals Council declined to review the decision. In the federal case, Collier moved for summary judgment, asking the court to award benefits or send the case back for a new hearing. The Commissioner filed a cross-motion for judgment on the pleadings, asking the court to uphold the administrative decision.

Issues and Arguments

Collier argued that the administrative law judge should have obtained testimony from a medical expert to determine whether his impairments equaled a listed impairment. He also argued that the judge failed to properly apply the treating-physician rule to the opinion of Dr. Silvio Ceccarelli, who reported severe pain and substantial limits on Collier’s ability to work.

The Commissioner argued that the administrative law judge was not required to obtain medical-expert testimony in these circumstances and properly evaluated the medical evidence and Dr. Ceccarelli’s opinion.

Court’s Analysis

The court reviewed whether the administrative law judge applied the correct legal standards and whether the decision was supported by substantial evidence. “Substantial evidence” means relevant evidence that a reasonable person could accept as enough to support a conclusion. The court reviewed the entire record, including evidence that supported and detracted from the denial, but explained that the court—not the reviewing judge—resolves evidentiary conflicts and decides witness credibility in the first instance.

The court rejected Collier’s medical-expert argument. It explained that an administrative law judge may request medical-expert evidence but generally is not required to do so. The court found that none of the situations identified in the opinion requiring such testimony existed here. It also noted that Collier did not identify the specific listed impairment he claimed required additional expert testimony.

The court also rejected Collier’s treating-physician argument. Under the treating-physician rule discussed in the opinion, a treating physician’s opinion receives controlling weight when it is well supported by accepted medical techniques and is not inconsistent with substantial evidence in the record. If the opinion does not receive controlling weight, the administrative law judge must consider factors such as the length and nature of the treatment relationship, supporting evidence, consistency with the record, and the physician’s specialty, and must give good reasons for the assigned weight.

The court found that Administrative Law Judge Gonzales followed those requirements. He identified Dr. Ceccarelli as Collier’s treating physician, considered the relevant factors, and sent Dr. Ceccarelli a supplemental questionnaire. The court agreed that Dr. Ceccarelli’s opinion that Collier could not perform even low-stress work was not consistent with his treatment records and the record as a whole. The court also found that the judge accounted for Collier’s limitations in the residual functional capacity assessment.

Disposition

The court found that the administrative law judge applied the correct legal standards and that the decision denying benefits was supported by substantial evidence. The Commissioner’s motion for judgment on the pleadings was GRANTED, and Collier’s motion for summary judgment was DENIED. The court declined to remand the case, directed the Clerk of Court to close the motions, and directed that the case be closed.