Boyd v. Commissioner of Social Security
6:15-cv-01067
M.D. Fla.Sep 13, 2016Background
- Roger M. Boyd appealed the Commissioner’s denial of DIB and SSI after an ALJ found him not disabled.
- Claimant has a seizure disorder (found severe by the ALJ) and significant psychiatric history including anger outbursts, mood swings, anxiety, and substance history.
- Relevant medical evidence included treatment notes from neurologist Dr. Jeremy Grimes (who opined claimant "unable to maintain any sort of consistent gainful employment"), a consultative psychologist Dr. Malcom J. Graham, III, and records from primary care and behavioral-health providers.
- The ALJ assigned an RFC limiting Boyd to simple, routine, repetitive tasks, limited public contact, and adequate interaction with supervisors/coworkers; he found claimant’s symptom testimony not entirely credible.
- Boyd challenged (1) the ALJ’s failure to state the weight given to treating/examining medical opinions, (2) an allegedly incomplete hypothetical to the VE, and (3) defects in the credibility determination.
- The district court affirmed, concluding any alleged errors were either not present, concerned non-medical-opinion statements, or were harmless.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ failed to state with particularity the weight given to medical opinions | Boyd: ALJ didn’t state weight/reasons for treating and examining opinions (Grimes, Bonney, Stewart‑Marchman, Graham) | Commissioner: Either no such medical‑opinion evidence exists or the statements were non‑medical/conclusory and reserved to the ALJ | Court: No reversible error — Grimes’s statement was conclusory (opinion on ability to work reserved); no opinion evidence from Bonney/Stewart‑Marchman; Graham’s exam was discussed and ALJ reasonably adopted more restrictive RFC supported by record |
| Whether hypothetical to VE omitted claimant’s limitations | Boyd: Hypothetical failed to include all functional limits because ALJ improperly discounted medical opinions | Commissioner: Hypothetical was proper because ALJ did not err in weighing opinions | Court: Rejected — hypothetical was adequate given absence of error on opinions |
| Whether ALJ’s credibility finding was supported | Boyd: ALJ used boilerplate and failed to give specific reasons | Commissioner: ALJ provided specific reasons including medication response, poor work history, criminal/substance history | Court: Rejected — ALJ articulated explicit, adequate reasons for partially discounting claimant’s subjective complaints |
| Whether any ALJ error was harmless | Boyd: Errors affected outcome | Commissioner: Any errors were harmless and would not change result | Court: Harmless or not error; decision affirmed |
Key Cases Cited
- Doughty v. Apfel, 245 F.3d 1274 (11th Cir. 2001) (explains SSA five‑step sequential evaluation)
- Foote v. Chater, 67 F.3d 1553 (11th Cir. 1995) (defines substantial evidence standard)
- Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (ALJ must state with particularity weight given to medical opinions and reasons)
- MacGregor v. Bowen, 786 F.2d 1050 (11th Cir. 1986) (failure to state weight given to treating opinions can be reversible error)
- Edwards v. Sullivan, 937 F.2d 580 (11th Cir. 1991) (courts must affirm where Commissioner’s findings are supported by substantial evidence)