Iglesias v. Commissioner of Social Security
1:20-cv-23265-BB
S.D. Fla.Oct 14, 2021Background
- Plaintiff Milagros Iglesias applied for SSDI and SSI alleging disability beginning April 26, 2017, from cervical spine, left shoulder and left ankle injuries, chronic pain, dizziness, and depression; claims denied administratively and by an ALJ; Appeals Council denied review.
- Medical history: October 2015 trauma, April 2017 cervical surgery, ongoing cervical disc herniations on 2019 MRI; left shoulder tendinitis/partial rotator cuff tear; intermittent left ankle swelling and pain.
- Treating and examining opinions: long‑time treating surgeon Dr. Moya (post‑op care, restrictions), single‑exam IME Dr. Voglino (permanent limitations, recommended further treatment), consultative psych and state‑agency reviewers (non‑severe or limited mental restrictions), and state medical consultant Dr. Arkin (light work).
- Hearing: Plaintiff testified to severe pain, limited sitting/walking, need for naps, and reduced lifting; VE testified that with the ALJ’s RFC alternative jobs existed (housekeeper, office helper, laundry sorter) but certain stricter mental limits would preclude past work and many jobs.
- ALJ decision: found severe impairments but not disabling, assessed an RFC for a reduced range of light work with specific physical and limited mental restrictions, discounted some subjective complaints and certain medical opinion weight, and concluded Plaintiff can perform other work.
- Magistrate Judge’s R&R: recommends denying Plaintiff’s summary‑judgment motion and granting the Commissioner’s, finding the ALJ applied correct law and that the RFC and opinion‑weighing are supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ’s RFC is supported by substantial evidence | RFC understates physical limits (standing/walking, lifting/carrying, reaching/handling) and ignores objective findings | ALJ reasonably weighed records, credibility, state consultant opinion supports light work | ALJ’s RFC supported by substantial evidence; no reweighing warranted |
| Whether ALJ erred in discounting Dr. Voglino’s opinion | ALJ lacked good cause; Voglino’s opinion is objective and consistent with imaging/treating notes | ALJ properly discounted one‑time exam opinion as vague, not function‑by‑function, used AMA guidelines, and preceded recommended treatments | ALJ permissibly accorded less weight to Voglino’s opinion |
| Whether the ALJ properly evaluated Plaintiff’s symptom testimony/credibility | Plaintiff’s subjective reports of disabling pain and functional limits are reliable | ALJ permissibly found inconsistencies (medication noncompliance, variable education reports, tax/unemployment reporting) and followed the two‑step analysis | ALJ’s credibility assessment and symptom evaluation upheld as supported by record |
Key Cases Cited
- Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (standard: ALJ decision must be supported by substantial evidence).
- Foote v. Chater, 67 F.3d 1553 (11th Cir. 1995) (court must review the record as a whole, favorable and unfavorable).
- Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (grids inapplicable when non‑exertional limits significant; use VE).
- Lewis v. Callahan, 125 F.3d 1436 (11th Cir. 1997) (RFC is what claimant can still do despite limitations).
- Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002) (when objective evidence does not fully corroborate pain, ALJ must evaluate credibility using other record evidence).
- Brown v. Sullivan, 921 F.2d 1233 (11th Cir. 1991) (no presumption of validity for ALJ’s legal conclusions).
- Cornelius v. Sullivan, 936 F.2d 1143 (11th Cir. 1991) (failure to apply correct law or provide sufficient reasoning mandates reversal).
- Hunter v. Comm’r of Soc. Sec., [citation="609 F. App'x 555"] (11th Cir. 2015) (harmless‑error principle for ALJ mistakes that do not affect the outcome).