Curtis H. Smith v. Richard S. Schweiker, Secretary of Health and Human Services

Summary

The Fifth Circuit reviewed the termination of Curtis H. Smith's Social Security Disability Insurance and Supplemental Security Income benefits. The court held that the Secretary's decision was not supported by substantial evidence because it inadequately weighed the treating physician's opinions, post-hearing medical evidence, and Smith's subjective complaints of pain. The court reversed and remanded for a full evaluation of the record.

Holdings

1. The Secretary's decision terminating Smith's disability benefits was not supported by substantial evidence when the record was considered as a whole.
2. The opinion of a treating physician with substantial familiarity with a claimant's injuries, treatment, and response should receive considerable weight absent good cause to the contrary.
3. Subjective complaints of pain and disability may not be disregarded merely because they lack complete support from objective clinical or laboratory findings.
4. The Appeals Council must adequately evaluate relevant post-hearing evidence bearing on disability; perfunctory adherence to the ALJ's decision is insufficient when the evidence could affect the determination.

Questions Presented

1. Whether substantial evidence on the record as a whole supported the Secretary's termination of Smith's disability benefits as of November 1977.
2. Whether the ALJ and Appeals Council properly evaluated the treating physician's evidence, Smith's subjective complaints of pain, and post-hearing medical evidence.
3. Whether the Secretary's decision could be sustained when it relied substantially on a one-time consultative examination and did not adequately address later evidence of continuing disability.

Disposition

reversed_and_remanded