HUNNICUTT v. COMMISSIONER OF SOCIAL SECURITY, 5:23-cv-00463

Plaintiff J.S.H. sought judicial review of a Social Security ALJ's decision denying her disability benefits claim.
Plaintiff alleged disability based on depression, herniated disc, diabetes, high blood pressure, anxiety, migraines, and post-rotator cuff surgery complications.
Her date last insured was March 31, 2022, and the claim period began March 10, 2018.
The ALJ found a single severe impairment: degenerative disc disease, with other impairments found non-severe.
The ALJ concluded that, despite limitations, Plaintiff could perform light work with several restrictions and thus was not disabled.
Plaintiff's challenge on appeal focused on whether the ALJ properly considered the limiting side effects of her medications in the RFC assessment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly considered medication side effects in assessing RFC	ALJ failed to account for Plaintiff's regular complaints of nausea, drowsiness, and dizziness from her medications, impacting her ability to work	The record does not show consistent or substantiated complaints of medication side effects limiting Plaintiff's function; ALJ properly considered available evidence	ALJ considered and discussed side effects; finding is supported by substantial evidence; Plaintiff's subjective complaints were not corroborated by the medical record

Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (establishes the standard for substantial evidence review and five-step disability evaluation)
Burgin v. Comm’r of Soc. Sec., 420 F. App’x 901 (11th Cir. 2011) (ALJ need only account for limitations that are supported by the record)
Swindle v. Sullivan, 914 F.2d 222 (11th Cir. 1990) (ALJ must only credit side effects if supported by evidence)