## Facts

- Jeffery Hines applied for Social Security disability insurance benefits, alleging disabling fatigue and severe pain caused by sickle cell disease (SCD).
- SCD can cause episodes of acute pain and fatigue and may lack objective clinical markers corresponding to pain severity.
- Hines’s treating hematologist, Dr. Myung Kil Jeon, treated him for about 17 years and opined Hines was fully disabled due to exertion-induced pain and fatigue and could not sustain full-time work.
- An Administrative Law Judge (ALJ) found Hines had severe impairments but retained the residual functional capacity (RFC) to perform sedentary work.
- In discounting Hines’s symptoms and Dr. Jeon’s opinion, the ALJ relied on the absence of objective findings such as organ damage, neurological deficits, swollen limbs, or similar abnormalities.
- A vocational expert testified that sedentary jobs existed for an individual who could work an eight-hour day with normal breaks; the ALJ relied on that testimony to deny benefits at step five.
- The Appeals Council denied review; the district court reversed and ordered benefits; the Commissioner appealed.

## Issues

1. Whether the ALJ applied the correct legal standard for evaluating subjective pain by requiring objective evidence of pain intensity or disabling effect after showing an impairment capable of causing pain.
2. Whether substantial evidence supported the step-five finding that Hines could perform full-time sedentary work when the vocational expert’s testimony assumed an eight-hour day and did not reflect limitations from pain and fatigue.
3. Whether the ALJ lawfully discounted the long-term treating specialist’s opinion that Hines could not sustain full-time work.

## Decision

- The Fourth Circuit affirmed the district court’s judgment reversing the Commissioner’s denial and upholding an award of benefits.
- The court held the ALJ applied an improper pain standard by effectively demanding objective proof of pain severity despite established SCD.
- The court held the ALJ’s RFC finding and reliance on vocational testimony were not supported by substantial evidence because the hypothetical did not include credibly established limitations from pain and fatigue.
- The court concluded the ALJ improperly disregarded the treating hematologist’s opinion, particularly given the nature of SCD and the longitudinal treatment relationship.

## Legal Principles

- A claimant must produce objective medical evidence of an impairment that could reasonably be expected to cause the alleged pain; once that showing is made, the claimant’s subjective evidence of pain may not be rejected solely for lack of objective corroboration of pain intensity or degree.
- Conditions whose disabling symptoms are difficult to measure objectively require evaluation of consistency and credibility rather than a demand for objective markers of symptom severity.
- A treating physician’s medical opinion is entitled to substantial (and potentially controlling) weight when well supported and not inconsistent with other substantial evidence; an ALJ must provide legally sufficient reasons for discounting it.
- Vocational expert testimony constitutes substantial evidence only if based on a hypothetical that accurately reflects all credibly established limitations, including limitations from pain and fatigue.
- At step five, the Commissioner bears the burden to show a significant number of jobs exist that the claimant can perform given the RFC and limitations.

## Conclusion

The Fourth Circuit held that, after objective proof of an impairment capable of causing pain is shown, an ALJ may not reject disabling pain allegations merely because their severity lacks objective confirmation; because the ALJ discounted consistent pain and fatigue evidence, rejected the treating specialist without adequate grounds, and relied on vocational testimony based on an incomplete hypothetical, the award of disability benefits was affirmed.


Hines v. Barnhart, 453 F.3d 559 (4th Cir. 2006)