Charles Huntley v. Social Security Administration, Commissioner, 683 F. App'x 830

Plaintiff Charles Huntley appealed the denial of disability insurance benefits under 42 U.S.C. § 405(g) after the ALJ denied benefits and the Appeals Council declined review.
Huntley argued the ALJ gave insufficient weight to two examining physicians, over-relied on a non-examining physician, and substituted the ALJ’s own views for medical opinions.
The ALJ assessed medical opinions under the five-step disability evaluation framework and applied the regulatory factors for weighing medical opinions (examining status, support, consistency, specialty, and explanation).
The ALJ gave little weight to the one-time examining physicians because their extreme limitation findings lacked supporting explanations and were inconsistent with their own examinations and the record.
The ALJ gave greater weight to a non-examining physician whose opinion included specific reasoning and was consistent with treatment records.
The Eleventh Circuit reviewed legal conclusions de novo and factual findings for substantial evidence and affirmed the Commissioner’s denial of benefits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ erred by giving little weight to examining physicians	Huntley: ALJ gave too little weight to examining physicians’ opinions	Commissioner: Examiners were one-time, gave no adequate explanations, and relied on subjective complaints	Affirmed: ALJ permissibly discounted those opinions for lack of support and explanation
Whether ALJ erred by giving weight to non-examining physician	Huntley: ALJ relied improperly on non-examining opinion over examiners	Commissioner: Non-examining opinion provided specific reasons and matched treatment records	Affirmed: ALJ could rely on non-examining opinion where consistent and well-explained
Whether ALJ substituted own medical judgment for experts	Huntley: ALJ impermissibly substituted his own opinion for medical experts	Commissioner: ALJ evaluated and weighed medical evidence under regulations	Affirmed: No improper substitution; ALJ’s conclusions supported by substantial evidence
Whether the ALJ’s decision is supported by substantial evidence	Huntley: Record supports greater limitations than ALJ found	Commissioner: Record and explanations support ALJ’s RFC determination	Affirmed: Substantial evidence supports weight given and ultimate decision

Doughty v. Apfel, 245 F.3d 1274 (11th Cir. 2001) (standards for review when Appeals Council denies review)
Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (de novo review of legal conclusions and substantial-evidence review of denials)
Winschel v. Comm’r, 631 F.3d 1176 (11th Cir. 2011) (ALJ must state with particularity weight given to medical opinions)
Crawford v. Comm’r, 363 F.3d 1155 (11th Cir. 2004) (court defers to Commissioner if supported by substantial evidence)
Ellison v. Barnhart, 355 F.3d 1272 (11th Cir. 2003) (claimant bears burden to prove disability)
Jones v. Apfel, 190 F.3d 1224 (11th Cir. 1999) (five-step sequential evaluation)
McSwain v. Bowen, 814 F.2d 617 (11th Cir. 1987) (no special deference to one-time examiner)
Swindle v. Sullivan, 914 F.2d 222 (11th Cir. 1990) (non-examining opinion alone cannot constitute substantial evidence)
Edward v. Sullivan, 937 F.2d 580 (11th Cir. 1991) (ALJ may rely on non-examining opinion when consistent with examining reports)
Sryock v. Heckler, 764 F.2d 834 (11th Cir. 1985) (ALJ may reject any physician’s opinion supported by contrary evidence)