## Facts

- Sara Angel applied for disability insurance benefits and supplemental security income, alleging disability from July 24, 1997 through December 31, 1999 due to back and bladder impairments.
- An ALJ found Angel had severe back and bladder impairments but determined at step three that her condition did not meet or equal Listing 1.05C (vertebrogenic disorders).
- Angel’s treating osteopath testified that her spinal injuries, combined with bladder dysfunction and loss of certain reflexes, met or equaled Listing 1.05C.
- The ALJ assessed an RFC for a wide range of light work, including: frequent lifting up to 10 pounds and maximum 20 pounds; standing/walking up to 2 hours at a time and up to 6 hours in an 8-hour day; occasional stooping; and self-catheterization for 10–15 minutes every 2 to 2.5 hours during the workday.
- Angel testified that pain limited her to lifting no more than a gallon of milk and standing, sitting, or walking no more than about 20 minutes at a time; her treating osteopath corroborated these limitations.
- Relying on vocational expert testimony, the ALJ found at step four that Angel could perform past relevant work, including insurance clerk, receptionist, accounts payable clerk, senior office assistant, convenience store clerk, and barmaid.
- The Appeals Council denied review, the district court affirmed the denial, and Angel appealed.

## Issues

1. Whether the ALJ applied the correct legal standards and had substantial evidence to reject the treating osteopath’s opinion that Angel’s impairments met or equaled Listing 1.05C.
2. Whether the ALJ’s adverse credibility finding regarding Angel’s subjective complaints of pain and limitation was closely linked to substantial evidence and adequately explained.
3. Whether errors in evaluating treating-source evidence and credibility undermined the RFC assessment and the step-four finding that Angel could perform past relevant work.

## Decision

- The Tenth Circuit reversed the district court’s judgment affirming the Commissioner and remanded for further proceedings.
- The court held the ALJ did not adequately explain the weight given to the treating osteopath’s opinion on listing equivalence.
- The court held the ALJ’s credibility determination rejecting Angel’s pain testimony was not supported by substantial evidence and was insufficiently explained, particularly given corroboration and objective findings consistent with her allegations.
- Because the RFC and step-four finding depended on the defective treating-source and credibility analyses, the denial of benefits could not stand.

## Legal Principles

- Judicial review asks whether the agency applied the correct legal standards and whether its findings are supported by substantial evidence.
- A treating-source opinion is entitled to controlling weight if well-supported by medically acceptable techniques and not inconsistent with other substantial evidence; if not controlling, the ALJ must give specific, legitimate reasons tied to regulatory factors.
- Step-three determinations must be explained with enough specificity to permit meaningful review, including consideration of combined impairments where relevant.
- Credibility findings on subjective symptoms must be closely and affirmatively linked to substantial evidence and cannot be stated as conclusory assertions.
- An RFC and step-four determination must rest on a legally adequate evaluation of treating-source opinions and subjective complaints; errors in those evaluations can require remand.

## Conclusion

The Tenth Circuit required remand because the ALJ failed to provide a sufficiently specific, legally grounded explanation for discounting the treating osteopath’s listing-equivalence opinion and for discrediting Angel’s pain testimony, which in turn undermined the RFC and step-four finding that she could return to past relevant work.


Angel v. Barnhart, 329 F.3d 1208 (10th Cir. 2003)