Donnell Mitchell v. Commissioner, Social Security Administration
771 F.3d 780
| 11th Cir. | 2014Background
- Donnell Mitchell applied for Supplemental Security Income (SSI) in 2009, alleging longstanding back pain and limited ability to stand or walk.
- An ALJ held a hearing (Dec. 7, 2010) and denied benefits (Jan. 3, 2011), finding Mitchell’s impairments could cause symptoms but discounting the credibility of his subjective complaints to the extent inconsistent with the ALJ’s RFC.
- Mitchell submitted additional medical records (nurse-practitioner notes, treating-physician notes, and a treating physician’s work-capacity opinion) to the Appeals Council when seeking review.
- The Appeals Council denied review, stating it considered the new evidence but that it did not provide a basis for changing the ALJ’s decision; it did not provide a detailed discussion of the new evidence.
- The district court adopted the magistrate judge’s recommendation to affirm; Mitchell appealed to the Eleventh Circuit challenging (1) the ALJ’s credibility finding and (2) the Appeals Council’s failure to discuss new evidence. The Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ’s credibility determination was supported by substantial evidence | ALJ improperly discredited Mitchell’s pain complaints; decision ignored favorable evidence | ALJ made a clearly articulated credibility finding supported by specific record reasons | Affirmed — ALJ’s credibility finding supported by substantial evidence; no requirement to cite every piece of evidence |
| Whether Appeals Council must explain its evaluation of new evidence when denying review | Appeals Council erred by not discussing the new evidence it accepted | Appeals Council stated it considered the evidence and may deny review without a detailed rationale if the evidence does not show error | Affirmed — Appeals Council not required to provide detailed rationale; record shows it considered the evidence and new evidence did not render denial erroneous |
Key Cases Cited
- Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (standard of substantial evidence review)
- Marbury v. Sullivan, 957 F.2d 837 (11th Cir. 1992) (review of ALJ credibility determinations for substantial evidence)
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (credibility determinations are for the ALJ)
- Foote v. Chater, 67 F.3d 1553 (11th Cir. 1995) (ALJ need not reference every piece of evidence if decision permits review of the record as a whole)
- Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (affirm where Commissioner’s decision is supported by substantial evidence)
- Mann v. Gardner, 380 F.2d 182 (5th Cir. 1967) (remand where Appeals Council perfunctorily adopted recommended decision and failed to evaluate new evidence)
- Epps v. Harris, 624 F.2d 1267 (5th Cir. 1980) (Appeals Council’s perfunctory adherence to ALJ decision when new evidence undermines ALJ rationale warrants remand)
- Bowen v. Heckler, 748 F.2d 629 (11th Cir. 1984) (Appeals Council must apply correct legal standards and consider combined effects of impairments)
- Ingram v. Comm’r of Soc. Sec., 496 F.3d 1253 (11th Cir. 2007) (Appeals Council may deny review after accepting new evidence if that evidence does not show error)