Eddie Sampson v. Commissioner of Social Security
694 F. App'x 727
| 11th Cir. | 2017Background
- Eddie Sampson applied (Aug 2007) for DIB and SSI alleging physical (diabetes with peripheral neuropathy, bilateral knee osteoarthritis, obesity, hypertension) and mental (bipolar/mood disorder, anger/impulse control) impairments; alleged onset Mar 22, 2007.
- Two administrative hearings: ALJ initially denied (Nov 2009); Appeals Council remanded; ALJ later found Sampson disabled beginning Sept 11, 2011, but not before.
- Treating and examining sources: Dr. Koscho (primary care, began 2006) and Dr. Villamagna (family medicine, began 2009) submitted restrictive opinions (limited sit/stand/walk); Dr. Klein (podiatrist, began 2010) opined severe limits from diabetic neuropathy; Dr. Moore (examiner at ALJ’s request) and treating notes provided mixed objective findings.
- ALJ gave little weight to most treating opinions (Koscho, Villamagna, Jackson) and gave limited/moderate weight to parts of Dr. Klein’s opinion; ALJ adopted an RFC of light work with additional limitations prior to Sept 11, 2011, and more restrictive sitting/standing limits after that date.
- District court affirmed; Eleventh Circuit reviewed for substantial evidence and legal error and vacated in part, remanding limited to the pre-Sept 11, 2011 period concerning Dr. Klein’s opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ gave "good cause" for discounting treating/exam opinions (esp. Dr. Klein) | Sampson: ALJ improperly rejected treating opinions without adequate reasons; Dr. Klein’s findings support substantial limitations | Commissioner: ALJ reasonably discounted opinions as inconsistent with treatment notes and observations | Court: ALJ lacked good cause to discount Dr. Klein’s opinion; remand required on that issue; other treating opinions (Koscho, Villamagna, Jackson) were permissibly discounted and affirmed |
| Whether ALJ adequately explained RFC before Sept 11, 2011 | Sampson: RFC not supported because ALJ rejected most medical opinions and relied on lay observations | Comm’r: ALJ permissibly discounted contrary opinions and explained RFC based on record evidence | Court: RFC supported by substantial evidence except to the extent it omitted Dr. Klein’s sitting/standing/ambulation limitations; remand to address that opinion |
| Whether ALJ improperly relied on hearing observations ("sit-and-squirm") to discredit testimony or medical opinions | Sampson: ALJ engaged in improper credibility reasoning by relying on claimant’s hearing demeanor | Comm’r: ALJ’s observations were used in context with medical evidence; not sole basis | Court: Some ALJ observations were problematic but harmless as to Koscho/Villamagna; observations regarding mental functioning were permissible when coupled with treatment records |
| Whether ALJ properly evaluated claimant’s credibility about symptoms | Sampson: ALJ failed to give explicit, adequate reasons to discredit pain and mental-symptom testimony | Comm’r: ALJ provided clear reasons (medical evidence, activities, treatment response) | Court: ALJ provided adequate, supported credibility findings for period before Sept 11, 2011; overall credibility ruling affirmed except as affected by Dr. Klein issue |
Key Cases Cited
- Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (ALJ must state clear reasons and decision must be supported by substantial evidence)
- Jones v. Apfel, 190 F.3d 1224 (11th Cir. 1999) (five-step sequential evaluation and burdens at steps four and five)
- Sharfarz v. Bowen, 825 F.2d 278 (11th Cir. 1987) (ALJ may reject medical opinion when evidence supports contrary finding)
- Orn v. Astrue, 495 F.3d 625 (9th Cir. 2007) (medical records primarily serve treatment purposes and do not automatically override physician opinion)
- Brownawell v. Comm’r of Soc. Sec., 554 F.3d 352 (3d Cir. 2008) (distinguishing treatment notes from a physician’s ultimate work-capacity opinion)
- Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (credibility determination must be explicit enough to permit meaningful review)
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (review standard: affirm if reasonable basis exists in record)