Gray v. Commissioner of Social Security
426 F. App'x 751
11th Cir.2011Background
- Gray appeals a district court order affirming the Commissioner’s July 2008 denial of disability insurance benefits and supplemental security income.
- Gray challenges the ALJ’s Step Two finding that her impairments were not severe enough to constitute a disability.
- The court reviews whether the ALJ applied the correct legal standard for severity and whether substantial evidence supports the findings on hypertension, anxiety, and depression.
- The ALJ found Gray’s medically determinable impairments did not significantly limit basic work activities, despite some impairments in the record.
- The court affirms, concluding the ALJ’s analysis was thorough and supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ applied the correct severity standard at Step Two | Gray argues the 'significantly limits' standard was misapplied. | Commissioner contends the ALJ used the regulatory language properly to assess severity. | ALJ did not apply an incorrect legal standard. |
| Whether substantial evidence supports the ALJ’s findings on hypertension, anxiety, and depression | Gray asserts the record shows more than minor limits from these impairments. | Commissioner contends evidence supports only minimal or no long-term limitations. | Substantial evidence supports the ALJ’s conclusion that impairments were not severe. |
| Whether the ALJ properly weighed medical opinions and malingering assessment | Gray challenges weight given to certain opinions and the malingering finding. | Commissioner asserts the ALJ appropriately weighed evidence and considered malingering. | ALJ’s weight assignments and malingering finding were proper; decision affirmed. |
Key Cases Cited
- Miles v. Chater, 84 F.3d 1397 (11th Cir. 1996) (do not presume proper standards; require exacting review)
- Martin v. Sullivan, 894 F.2d 1520 (11th Cir. 1990) (failure to apply correct legal standards mandates reversal)
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (disability defined; 12-month duration requirement)
- Crayton v. Callahan, 120 F.3d 1217 (11th Cir. 1997) (severity means significant limitation of basic work activities)
- McCruter v. Bowen, 791 F.2d 1544 (11th Cir. 1986) (severity measured by effect on ability to work)
- Brady v. Heckler, 724 F.2d 914 (11th Cir. 1984) (not severe if impact on work is minimal)
- Crawford v. Comm'r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (substantial evidence standard governs review)