Devilder v. Commissioner of Social Security, 2:15-cv-00421

Sara Devilder applied for disability insurance benefits alleging fibromyalgia, depression, and chronic fatigue with an onset date of June 1, 2011; application was denied and ALJ issued an adverse decision on March 7, 2014; Appeals Council denied review.
ALJ found severe impairments including fibromyalgia, cervical/lumbar degenerative changes, obesity, ADHD, dermatotillomania, bipolar disorder, and anxiety, but did not find any Listing met or equaled.
ALJ assessed an RFC for light work with multiple nonexertional limits (frequent posturals, occasional ladders, avoidance of hazards, simple routine work, limited coworker/supervisor contact, no public contact).
At step five, with transferred skills, ALJ relied on VE testimony to find claimant could perform jobs existing in significant numbers (photocopy operator, laundry sorter, mail room sorter) and denied benefits.
The sole issue on appeal: whether the ALJ properly weighed the long-term treating psychiatrist Dr. Roxann Sangiacomo’s December 2013 medical assessment that rated several marked/poor limitations (including no ability to deal with work stress).
ALJ gave Dr. Sangiacomo’s opinion little weight, finding it unsupported by objective clinical findings and inconsistent with the record (improvement on medication, largely normal mental status exams, treating PCP and other providers documenting stability). Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ properly weighed treating psychiatrist’s opinion	Devilder: ALJ failed to give proper weight and ignored the portion finding poor/no ability to deal with work stress	Commissioner: ALJ gave valid reasons (opinion unsupported by clinical findings and inconsistent with record showing improvement and normal exams)	Court: Affirmed ALJ; substantial evidence and good cause to give opinion little weight

Winschel v. Comm'r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (treating physician rule and when ALJ must articulate reasons for not giving controlling weight)
Crawford v. Comm'r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (scope of district court review; ALJ credibility determinations)
Foote v. Chater, 67 F.3d 1553 (11th Cir. 1995) (definition of substantial evidence and review as whole-record inquiry)
Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (ALJ not required to reference every piece of evidence)
Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (good cause to discount treating opinion where unsupported, inconsistent, or conclusory)
Hunter v. Soc. Sec. Admin., Comm'r, 808 F.3d 818 (11th Cir. 2015) (deference to ALJ factfinding)
Newberry v. Comm'r, Soc. Sec. Admin., [citation="572 F. App'x 671"] (11th Cir. 2014) (harmless-error approach to challenges over weighing medical opinion)