Elizabeth Wood v. Commissioner of Social Security Administration, 21-1905

Background

Elizabeth A. Wood appealed the district court’s order (adopting a magistrate judge’s recommendation) affirming the Commissioner’s denial of disability insurance benefits.
Medical sources included: consultative psychologist David S. Leen, PhD; treating psychiatrist Mahmudur Rabbi, M.D.; and licensed clinical social worker Victoria S. McClave.
The ALJ discounted various opinion components, finding them inconsistent with treatment records, mental-status exams, and Wood’s activities (consistent part‑time work, international travel including zip‑lining, church attendance, household tasks).
The ALJ found Wood’s symptoms were fairly controlled with conservative treatment (medication and counseling) and incorporated some restrictions into the RFC (low‑stress work, no fast‑paced production, limited public/supervisor interaction).
Wood argued the ALJ failed to adequately apply the 20 C.F.R. § 404.1527(c) factors, provided conclusory reasoning, and improperly discounted treating and other medical opinions.
The district court affirmed; the Fourth Circuit affirmed, holding the ALJ applied correct legal standards and reached conclusions supported by substantial evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ meaningfully considered 20 C.F.R. § 404.1527(c) factors for consultative psychologist Leen	ALJ failed to analyze each factor and gave conclusory reasons for discounting Leen’s opinion	ALJ noted Leen’s credentials, exam history, and discounted the opinion as inconsistent with treatment records, objective exams, activities, and reliance on subjective complaints	Affirmed — ALJ meaningfully considered factors; discounting supported by substantial evidence
Whether ALJ properly evaluated opinion of non‑acceptable medical source McClave (LCSW)	McClave’s opinion should carry weight and ALJ’s discounting was improper	McClave is not an acceptable medical source; ALJ permissibly gave little weight because notes and activities contradicted disabling limitations	Affirmed — ALJ properly weighed non‑acceptable source and relied on record inconsistencies
Whether ALJ properly evaluated treating physician Rabbi’s opinions	Rabbi was a treating psychiatrist; his opinion of debilitating impairment should be controlling	ALJ found Rabbi’s notes did not show signs of depression/anxiety consistent with disabling limitations and that treatment response and activities contradicted extreme conclusions	Affirmed — ALJ considered treating status, supportability, and consistency; substantial evidence supports giving less weight
Whether ALJ reasonably incorporated medical opinions into the RFC and discounted checkbox/disability forms	ALJ failed to adopt limiting conclusions and ignored some opinion evidence	ALJ incorporated many restrictions (low stress, limited interaction) and permissibly discounted conclusory checkbox forms that lacked supporting clinical evidence	Affirmed — RFC accounted for relevant limitations and discounting of checkbox forms was proper

Key Cases Cited

Bird v. Comm’r of Soc. Sec. Admin., 699 F.3d 337 (4th Cir. 2012) (appellate review limited to whether ALJ applied correct legal standards and findings are supported by substantial evidence)
Hancock v. Astrue, 667 F.3d 470 (4th Cir. 2012) (definition of substantial evidence)
Radford v. Colvin, 734 F.3d 288 (4th Cir. 2013) (court may not reweigh evidence or substitute its judgment for ALJ)
Lewis v. Berryhill, 858 F.3d 858 (4th Cir. 2017) (treating‑physician opinion is entitled to controlling weight if well‑supported and consistent)
Hines v. Barnhart, 453 F.3d 559 (4th Cir. 2006) (treating physician rule rationale and that it is not absolute)
Johnson v. Barnhart, 434 F.3d 650 (4th Cir. 2005) (nonexclusive factors for weighing medical opinions)
Dowling v. Commissioner, 986 F.3d 377 (4th Cir. 2021) (ALJ must meaningfully consider the § 404.1527(c) factors even if not itemized factor‑by‑factor)
Anderson v. Astrue, 696 F.3d 790 (8th Cir. 2012) (conclusory checkbox forms have little evidentiary value)