Anne Huigens v. Social Security Administration, Commissioner, 17-11682

Huigens filed for disability insurance benefits and supplemental security income alleging disability from December 2, 2009, due to osteoarthritis, chronic pain, depression, bipolar disorder, and anxiety; hearings occurred in 2012 and 2014.
Medical records from Quality of Life Health Services showed diagnoses of osteoarthritis, myalgia/myositis, and chronic pain syndrome with mostly conservative treatment (medication) and clinical findings described as mild with mildly reduced range of motion.
Two treating physicians (Drs. Tariq and Scarborough) completed physical-capacity forms indicating severe limitations (e.g., frequent need to lie down, very limited sitting/standing/walking durations); the ALJ gave those opinions little weight as inconsistent with their treatment notes and other evidence.
The ALJ found Huigens capable of a reduced range of light work with sit/stand option, simple instructions, limited public contact, and other mental-health–related restrictions; concluded she could not perform past relevant work but could perform other jobs in the national economy, so not disabled.
The Appeals Council denied review of the disability-insurance denial but granted supplemental security income starting June 5, 2013 (Huigens’s 55th birthday), using the Medical-Vocational Guidelines (Grids) and classifying her as "closely approaching advanced age" prior to that date.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight given to treating physicians' opinions	Huigens: ALJ erred in discounting treating doctors’ opinions about severe physical limitations	Commissioner: ALJ properly discredited opinions as inconsistent with treating notes and other record evidence	Affirmed — ALJ articulated good cause and substantial evidence supports discounting those opinions
Use of Medical-Vocational Guidelines (age/borderline age)	Huigens: Appeals Council mechanically applied Grids/should have treated her in older age category (borderline)	Commissioner: Appeals Council considered education, skills, and RFC; used Grids as framework and properly used chronological age	Affirmed — Council did not mechanically apply the Grids and substantial evidence supports using chronological age prior to 6/5/2013
Need for remand under SSR 16-3p	Huigens: SSR 16-3p requires reassessment of subjective symptom evaluation and should apply retroactively	Commissioner: SSR 16-3p is prospective; ALJ’s credibility assessment was consistent with both SSRs	Affirmed — SSR 16-3p is not retroactive (per Eleventh Circuit precedent) and no reversible error in symptom evaluation
Use of RFC in step‑5 analysis	Huigens: RFC did not adequately capture limitations so step‑5 finding is unsound	Commissioner: RFC based on substantial evidence, and VE/Grids support ability to perform other work	Affirmed — RFC supported by substantial evidence and step‑5 finding stands

Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (RFC determination and Grids use explained)
Winschel v. Commissioner of Social Security, 631 F.3d 1176 (11th Cir. 2011) (treating physician weight and "good cause" standard)
Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (substantial evidence review of ALJ’s reasons)
Walker v. Bowen, 826 F.2d 996 (11th Cir. 1987) (prohibition on mechanical application of Grids based solely on age)
Reeves v. Heckler, 734 F.2d 519 (11th Cir. 1984) (claimant must produce substantial credible evidence to rebut Grids’ adaptability inference)
Hutchison v. Bowen, 787 F.2d 1461 (11th Cir. 1986) (limitations used to create RFC are insufficient alone to show additional adversities for borderline age)
Hargress v. Social Security Administration, 874 F.3d 1284 (11th Cir. 2017) (SSR 16-3p applies prospectively)
Gibson v. Heckler, 762 F.2d 1516 (11th Cir. 1985) (description of the Medical-Vocational Guidelines)
Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002) (Grids may be used as a framework alongside VE testimony)
Sryock v. Heckler, 764 F.2d 834 (11th Cir. 1985) (ALJ may reject medical opinion supported by contrary evidence)