Wright v. Commissioner of Social Security

Citation: 386 F. App'x 105Docket: No. 09-2447

Court: Court of Appeals for the Third Circuit; July 7, 2010; Federal Appellate Court

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Barry Wright appeals the District Court’s affirmation of the Commissioner of Social Security's denial of his application for Social Security Disability Insurance Benefits and Supplemental Security Income. The court's review focuses on whether substantial evidence supports the Commissioner’s decision. Substantial evidence is defined as adequate evidence that a reasonable mind might accept to support a conclusion. Wright, a 59-year-old with a GED and an associate’s degree in small business management, has work experience as a longshoreman. He sought treatment for anxiety following a workplace incident in July 2005, despite sustaining no physical injuries. Wright applied for benefits on May 30, 2006, claiming disability due to post-traumatic stress disorder (PTSD) stemming from the incident. After his application was denied, he requested a hearing before an Administrative Law Judge (ALJ), which took place on September 13, 2007, where he was represented by an attorney.

During the hearing, Wright expressed significant emotional distress and described difficulties in daily life. However, the ALJ found his claims about the severity of his symptoms not entirely credible and concluded that he was not disabled, as he had the capacity to adjust to other work available in the national economy. The Appeals Council upheld the ALJ’s decision, and the District Court later ruled in favor of the Commissioner. In his appeal, Wright contends that the ALJ improperly discounted his treating psychiatrist's opinion and questioned his credibility. To establish disability under the Social Security Act, a claimant must show a medically determinable impairment that prevents engagement in substantial gainful activity for at least twelve months. The ALJ follows a five-step evaluation process to determine disability status.

The claimant, Wright, bears the burden of proof through the first four steps of the Social Security disability evaluation process, while the Commissioner must prove at step five the availability of a significant number of suitable jobs in the national economy. The Administrative Law Judge (ALJ) applied this five-step process, determining that Wright's PTSD was a severe impairment but did not meet the strict criteria for listed impairments. The ALJ concluded that although Wright could not return to his previous work as a longshoreman, he retained the Residual Functional Capacity (RFC) to perform work at all exertional levels, specifically simple, repetitive tasks with low social contact. Consequently, the ALJ found Wright not disabled as he could perform jobs such as commercial cleaner.

Wright argued that the ALJ improperly discounted the opinion of his treating psychiatrist, Dr. Doyle, who indicated in August 2007 that Wright was "extremely limited" in several work-related activities. A treating physician's opinion is generally given controlling weight if well-supported and consistent with substantial evidence. However, the ALJ identified several inconsistencies in Dr. Doyle’s assessments, particularly in relation to consultative examinations conducted by Dr. Wolfram Rieger, who agreed with the PTSD diagnosis but believed Wright was not totally disabled and had shown improvement. Additionally, Dr. Rieger asserted that Wright could return to work, contradicting Dr. Doyle’s claims.

The ALJ also noted discrepancies between Dr. Doyle's findings and the testimony of Dr. Saul, who opined that Wright was capable of simple, routine work. Furthermore, the ALJ found inconsistencies within Dr. Doyle's own treatment notes, which suggested a plan for Wright's gradual return to work and indicated only slight to marked limitations, contrasting sharply with the extreme limitations stated in the August 2007 report without adequate explanation for the shift. Wright claimed the ALJ erred in noting Dr. Doyle's last treatment date and in citing other stressors as factors, but these errors were deemed minor and harmless.

The conclusion reached is that the ALJ provided sufficient justification, supported by substantial evidence, for giving less weight to Dr. Doyle’s August 2007 report. Wright argued that the ALJ erred in deeming his statements regarding the intensity, persistence, and effects of his symptoms as not entirely credible. The ALJ is required to consider a claimant's testimony when it is backed by competent evidence, as established in relevant case law. However, the record lacked objective medical evidence to substantiate Wright’s claims of pain and other symptoms. Dr. Rieger opined that Wright appeared to be prolonging his workers' compensation case to maintain a partial disability status for potential gains in third-party litigation. Additionally, Dr. Rieger noted that Wright exaggerated in his responses to the Minnesota Multiphasic Personality Inventory (MMPI), and his credibility was compromised by his testing behavior. The MMPI results indicated that Wright might have schizophrenia or a delusional disorder, which Dr. Rieger found to be unsubstantiated clinically. Therefore, the evidence strongly supports the ALJ’s credibility determination. The judgment of the District Court is affirmed, which had jurisdiction under 42 U.S.C. 405(g), and appellate jurisdiction is established under 28 U.S.C. 1291. Work-related activities assessed included the ability to understand and carry out detailed instructions, make simple work-related judgments, and interact appropriately in a work setting.