Thomas v. Astrue
An opinion of a physician who examines and treats an individual generally has greater authority, especially if the opinion is properly documented and consistent with medical evidence. Cheryl Thomas suffers from carpal tunnel syndrome and requested Social Security benefits. Thomas' application was denied, and she argued that the defendant commissioner of Social Security Administration violated the "treating physician rule." Thomas claimed that the administrative law judge did not consider her treating doctor's 2011 opinion. The District Court found that the administrative law judge could not have considered the opinion, which was issued after the administrative law judge ruled. Thomas' doctor indicated Thomas can sit for six hours per day, occasionally lift more than 10 pounds and is likely to be absent from work three days per month, as a result of medical visits or disability. Generally, the opinion was consistent with the administrative law judge's conclusions. An exception existed in that the treating doctor indicated Thomas could use her hands to grasp, turn and twist objects only 20 percent of the work day and could use her arms only 50 percent of the work day. The administrative law judge did not reach similar conclusions about Thomas' abilities to grasp and to use her arms. The treating doctor's 2011 opinion was submitted to the Social Security Appeals Council, which found that the opinion did not provide a basis to change the administrative law judge's decision. The District Court agreed that the 2011 opinion did not merit reversal. Substantial evidence contradicted the 2011 opinion. In September 2009, the same doctor concluded Thomas could use her hands 100 percent of the time and her arms 80 percent of the time. A specialist who examined Thomas found only mild evidence of neuropathy bilaterally, without motor involvement. "Because [the treating doctor's] opinion was not consistent with other substantial evidence in the record," wrote the court, "including the opinions of other medical experts, the Commissioner was not obligated to give it controlling weight." The decision to deny disability benefits did not violate the treating physician rule, and the District Court granted the commissioner's motion to affirm.