Carrie B. Lee v. Commissioner, Social Security Administration
551 F. App'x 539
11th Cir.2014Background
- Carrie Lee appeals a district court decision affirming an ALJ denial of DIB and SSI benefits.
- Lee challenged the ALJ’s hypothetical to the VE for not accounting for concentration, persistence, and pace limitations.
- Lee argued the ALJ erred by not relying on Dr. Carstens’s Work Status Reports restricting to sedentary work.
- Lee contended the ALJ gave insufficient weight to psychiatrists’ and psychologists’ opinions.
- Court reviews ALJ decisions de novo on legal issues and for substantial evidence on factual findings in the SSA five-step framework.
- The court ultimately affirmed the ALJ’s decision on all challenged aspects.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Hypothetical to VE sufficiency | Lee’s concentration/pacing impairments not in VE question. | ALJ implicitly accounted via simple-work limitation. | Hypothetical adequately accounted for impairments; affirmed. |
| Work restrictions from treating physician | Carstens’s sedentary-work restrictions should be adopted. | No post-2009 restrictions; substantial evidence supports RFC. | ALJ properly declined to rely on Carstens’s reports; affirmed. |
| Weight to psychiatrists/psychologists | Experts supported disability and listing-level impairments. | Opinions are medical but disability determination is legal; not supported by evidence. | ALJ properly weighed opinions; affirmed. |
Key Cases Cited
- Winschel v. Comm’r, Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (hypothetical must include all impairments; simple-work limitation insufficient alone)
- Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002) (VE testimony must be based on a complete hypothetical)
- Doughty v. Apfel, 245 F.3d 1274 (11th Cir. 2001) (review of ALJ decision as final decision of Commissioner)
- Lewis v. Callahan, 125 F.3d 1436 (11th Cir. 1997) (treating-physician weight and good cause standard)
- Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (treating physician opinions and evidence supportability)
- Jones v. Apfel, 190 F.3d 1224 (11th Cir. 1999) (burden-shifting at fifth step; claimant must show no past work)
- Johns v. Bowen, 821 F.2d 551 (11th Cir. 1987) (listing determinations reserved to Commissioner)
- Barron v. Sullivan, 924 F.2d 227 (11th Cir. 1991) (listing impairment analysis; medical evidence standards)