Opinion

Brown v. Commissioner Social Security Administration

  • 873 F.3d 251
  • 2017 U.S. App. LEXIS 18856
  • 2017 WL 4320263
Court
Court of Appeals for the Fourth Circuit
Filed
Sep 29, 2017
Status
Published
Author
Niemeyer
On the bench
Niemeyer, King, Wynn
Cited by
604 cases

finding error when the ALJ identified activities of daily living Plaintiff performed but failed to acknowledge “the extent of those activities” or any explanation “as to how those particular activities—or any of the activities depicted by [the plaintiff]|—-showed that he could persist through an eight-hour workday”

How later courts described this case

  • finding error when the ALJ identified activities of daily living Plaintiff performed but failed to acknowledge “the extent of those activities” or any explanation “as to how those particular activities—or any of the activities depicted by [the plaintiff]|—-showed that he could persist through an eight-hour workday”
  • holding an ALJ erred by discrediting a claimant’s symptom testimony based on “daily activities” where the “ALJ did not acknowledge the extent of those activities” and “provided no explanation as to how those particular activities . . . showed that he could persist through an eight-hour workday”
  • finding that statement by ALJ that claimant’s daily activities supported an adverse credibility determination was insufficient when AL] failed to note limited extent of the activities or explain how they showed he could sustain a full-time job
  • holding the ALJ erred in finding the plaintiff’s ADLs were inconsistent with his statements of pain because the ALJ did not consider the limited extent to which the plaintiff engaged in those activities; for example, the ALJ noted the plaintiff could drive but did not acknowledge the plaintiff stated he could drive only short distances without significant discomfort

Written by the judges who cited it.

The opinion

NIEMEYER, Circuit Judge,

dissenting:

In denying Brown’s claim for disability benefits, the ALJ considered the medical evidence and evaluated it together with Brown’s own extensive testimony. While the ALJ concluded that Brown suffered from several impairments that could reasonably be expected to cause his alleged symptoms, he also concluded that Brown’s testimony about “the intensity, persistence and limiting effects” of those symptoms was exaggerated and materially incredible. The ALJ went into substantial detail, pointing out discrepancies between Brown’s statements and other evidence, including the objective medical evidence. At bottom, because I conclude that the ALJ’s conclusions were supported by substantial evidence, I would affirm.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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