416 F. App'x 861
11th Cir.2011Background
- Annette Williams appeals the district court’s denial of disability benefits under 42 U.S.C. §§ 405(g) and 1383(c)(3).
- The ALJ gave little weight to Dr. Linda Abeles’s diagnosis of a psychotic disorder and relied more on a two-year-earlier diagnosis that did not indicate such a disorder.
- Williams argues the ALJ failed to consider impairments in combination and relied on a single, outdated medical opinion.
- The court reviews for substantial evidence and defers to the Commissioner on factual findings while rigorously examining legal conclusions.
- The five-step sequential evaluation governs disability determinations, with burden on Williams to show a severe impairment or combination of impairments.
- The ALJ must consider medical opinions and the record as a whole to determine severity and residual functional capacity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ properly weigh Dr. Abeles's psychotic-disorder diagnosis? | Williams contends Abeles’s opinion should be given weight as a psychotic-disorder diagnosis. | Williams argues Abeles’s opinion is unsupported and contradicted by clinical tests and other records. | Yes; ALJ properly gave little weight to Abeles. |
| Was the psychotic disorder properly considered in combination with other impairments? | Williams argues the psychotic disorder should be treated in combination with other impairments. | Defendant contends substantial evidence shows the psychotic disorder is not severe and need not be combined with other impairments. | Yes; ALJ did not find a severe psychotic disorder and did not consider it in combination. |
| Did the record support the ALJ’s overall determination under the five-step framework? | Williams asserts the analysis failed to account for all impairments. | Defendant asserts substantial evidence supports the ALJ’s stepwise findings. | Affirmed; substantial evidence supports upholding the five-step evaluation outcome. |
Key Cases Cited
- Martin v. Sullivan, 894 F.2d 1520 (11th Cir. 1990) (deferential review of factual findings; legal conclusions require more scrutiny)
- Sharfarz v. Bowen, 825 F.2d 278 (11th Cir. 1987) (more evidence supports rejecting an opinion when record contains contrary evidence)
- Wilson v. Apfel, 179 F.3d 1276 (11th Cir. 1999) (ALJ need not seek additional expert testimony when record is sufficient)
- Crayton v. Callahan, 120 F.3d 1217 (11th Cir. 1997) (psychiatric impairment not necessarily fatal to stepwise analysis)
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (very heavy burden on claimant to prove disability; consider impairments alone and in combination)
- Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (second step requires evaluating severity of impairments alone and in combination)