Denney v. Social Security Administration, Commissioner, 1:11-cv-02099

Plaintiff Susan Denney applied for DIB and SSI asserting disability beginning October 31, 2008 due to migraines and related symptoms.
The SSA denied the claims; an ALJ held a hearing and, on December 3, 2010, found Denney not disabled.
The Appeals Council denied review; the district court has jurisdiction to review under 42 U.S.C. §§ 405(g) and 1383(c)(3).
The ALJ determined Denney had severe migraines and obesity but did not meet or equal a listed impairment and maintained a light-RFC with specific restrictions.
The ALJ credited some evidence (e.g., Estock’s psychiatric view) and found Dr. Rahim’s opinion not controlling due to inconsistency with records and imaging.
A vocational expert testified that a person with Denney’s RFC could not perform past work or other full-time work, but the ALJ ultimately concluded past work as a cashier was still available after considering the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the ALJ properly weigh the treating physician's opinion under the three-part pain standard?	Rahim’s opinion should be given controlling weight as treating doctor.	Good cause exists to discount Rahim due to inconsistency with treatment notes and objective evidence.	Yes; ALJ had good cause to discount Rahim and properly applied the three-part pain standard.
Whether the ALJ properly relied on Dr. Estock and found no severe mental impairment?	Mental impairment evidence supports greater limitation.	Estock’s assessment showing no severe mental impairment is supported by record.	Yes; ALJ's reliance on Estock is supported by substantial evidence.

Holt v. Sullivan, 921 F.2d 1223 (11th Cir. 1991) (three-part pain standard applies with objective support or severity to justify pain complaints)
Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002) (context for evaluating pain and credibility evidence)
Crawford v. Comm’r, 363 F.3d 1155 (11th Cir. 2004) (treating physician rule and weight owed to treating opinions)
Lewis v. Callahan, 125 F.3d 1436 (11th Cir. 1997) (good cause to disregard treating opinions when not bolstered by evidence)
McDaniel v. Bowen, 800 F.2d 1026 (11th Cir. 1986) (applies standard evaluation framework for SSI/SSA disability claims)