Arakas v. Commissioner, Social Security Administration

983 F.3d 83 (2020)

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Arakas v. Commissioner, Social Security Administration

United States Court of Appeals for the Fourth Circuit
983 F.3d 83 (2020)

  • Written by Angela Patrick, JD

Facts

Esin Arakas (plaintiff) applied to the Social Security Administration (SSA) (defendant) for disability-insurance benefits on the grounds that she experienced disabling pain due to fibromyalgia and other issues. Dr. Frank Harper had treated Arakas for these conditions for approximately 20 years. Harper provided evidence that Arakas had physical evidence of trigger points consistent with fibromyalgia and that Arakas had reported multiple symptoms consistent with fibromyalgia. Harper also testified that these symptoms made it impossible for Arakas to work full time. The administrative-law judge (ALJ) denied Arakas’s claim entirely. The ALJ focused heavily on his belief that the medical records did not reveal the type of clinical and laboratory abnormalities, such as a limited range of motion, that the ALJ expected a disabled person to have. The ALJ gave no weight to Arakas’s subjective complaints of pain because he believed they were inconsistent with the objective medical evidence. The ALJ also gave little weight to Harper’s opinions about Arakas’s condition, again because the ALJ believed there was not sufficient objective medical evidence to support them. In contrast, the ALJ gave great weight to the opinion of state employees who had conducted a single exam of Arakas. After further proceedings, the federal district court affirmed the ALJ’s order denying Arakas’s claim. Arakas appealed to the United States Court of Appeals for the Fourth Circuit.

Rule of Law

Issue

Holding and Reasoning (Wynn, J.)

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Casebooks

Administrative Law

Key Terms

  • AcquiescenceFailure to act or object when one is aware of actions by another that may alter legal rights or the legal relationship between parties. In the trademark-infringement context, acquiescence is an equitable defense that applies if the defendant was prejudiced by his reliance on the trademark owner’s statement that he was allowed to use the trademark.
  • Administrative-Law Judge (ALJ)An official who presides over an administrative-type bench trial to resolve a dispute between a government agency and an individual.
  • Social Security AdministrationThe federal agency charged with administering Social Security benefits.
  • PrecedentA principle formed from an earlier decision that should lead to a similar outcome under similar circumstances.
  • Intracircuit nonacquiescenceAn administrative agency’s refusal to abide by circuit court precedent within the circuit court’s jurisdiction in the absence of a specific order in a particular case.
  • Acquiescence RulingA document that explains how the Social Security Administration will apply a holding on a question of law by a United States court of appeals within that court’s circuit when the holding differs from the Social Security Administration’s existing policy regarding the question of law.
  • Social Security Disability InsuranceA federally administered program providing benefits for insured wage earners who become disabled.
  • Social SecurityA national insurance program, funded by taxes paid by employees and employers, that provides retirement or disability benefits to the insured and the insured’s dependents. Social Security is not needs-based.
  • Treating-Physician RuleA rule requiring the decision-maker in a Social Security disability claim to give great weight to the opinion of the claimant’s treating physician unless persuasive evidence contradicts that opinion.

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