Summary
The United States Court of Appeals for the Third Circuit affirmed the denial of Alice Louise Smith’s claims for Disability Insurance Benefits and Supplemental Security Income. The court held that the administrative law judge properly declined to give controlling weight to the treating physician’s opinion and reasonably evaluated Smith’s complaints of pain, and that the decision was supported by substantial evidence.
Topics
Practice areas
Questions Presented
- Whether the ALJ erred by failing to give controlling weight to the opinion of Smith's treating physician.
- Whether the ALJ erred by failing to fully credit Smith's subjective complaints of pain.
- Whether the Commissioner's determination that Smith was not disabled was supported by substantial evidence.
Holdings
- The ALJ did not err in refusing to give controlling weight to the treating physician's opinion because the opinion was not well supported by medically acceptable clinical and laboratory diagnostic techniques and was inconsistent with other substantial evidence in the record.
- The ALJ did not err in declining to fully credit Smith's complaints of pain because the ALJ addressed those complaints and substantial evidence supported the finding that the pain was not as intense or debilitating as alleged.
- The Commissioner's determination that Smith was not disabled was supported by substantial evidence.
Key quotations
“Substantial evidence is “more than a mere scintilla, but may be somewhat less than a preponderance.”” (at 314)
“It means such relevant evidence as a reasonable mind might accept as adequate.” (at 314)
“Since, as set forth above, Dr. Rasheed’s medical opinion is contradicted by several pieces of evidence in the record and also contains internal inconsistencies, it is not entitled to the level of deference otherwise accorded to a treating physician’s opinion.” (at 316)
“The ALJ did not err in failing to accord controlling weight to the opinion of Smith’s treating physician, nor did he err in failing to fully credit Smith’s complaints of pain.” (at 318)
Factual background
Smith alleged disability beginning December 5, 2003, based on degenerative disk disease and gastroesophageal reflux disease. Her treating physician opined that she could sit, stand, and walk for only one hour each day and could perform no postural activities, while a consultative examiner found a full range of motion, normal gait, and no functional limitation in sitting, standing, walking, lifting, or grasping. Smith also testified that severe, constant pain prevented her from working, although the record showed that she cared for her young child for at least two years and often used over-the-counter pain medication.
Procedural history
After Smith's applications were denied initially and on reconsideration, an administrative law judge held a hearing and determined that Smith was not disabled. The Appeals Council denied review, making the ALJ's decision the Commissioner's final decision. The United States District Court for the Western District of Pennsylvania affirmed the Commissioner's decision after denying Smith's motion for summary judgment and granting the Commissioner's motion. Smith timely appealed.