Betty Holladay v. Otis Bowen, as Secretary of United States Department of Health and Human Services

Summary

The Eleventh Circuit affirmed the denial of Betty Holladay's application for Supplemental Security Income benefits. The court upheld the Secretary of Health and Human Services' regulation barring the purchase of coronary arteriography and concluded that the administrative law judge sufficiently developed the record without ordering the procedure. The court also held that vocational-expert testimony was not required because the claimant's residual functional capacity for sedentary work was adequately established.

Holdings

1. The Secretary's regulation providing that coronary arteriography is not to be purchased by the Social Security Administration is valid because it is consistent with 42 U.S.C. § 405(a) and is not arbitrary and capricious.
2. The ALJ did not commit reversible error by failing to obtain a coronary arteriogram because the absence of that test did not prevent the ALJ from making an overall disability determination supported by substantial evidence.
3. The ALJ was not required to obtain vocational-expert testimony before completing the sequential evaluation and relying on the Medical-Vocational Guidelines.

Questions Presented

1. Whether the Secretary's regulation prohibiting the Social Security Administration from purchasing coronary arteriography was valid under 42 U.S.C. § 405(a) and consistent with the ALJ's duty to develop a full and fair record.
2. Whether the ALJ reversibly erred by failing to obtain or authorize a coronary arteriogram before determining that Holladay did not meet a listed impairment.
3. Whether the ALJ was required to obtain vocational-expert testimony before relying on the Medical-Vocational Guidelines to find Holladay not disabled.

Disposition

affirmed