557 F. App'x 849
11th Cir.2014Background
- James E. Castle applied for DIB alleging onset Jan 1, 2008; insured through Mar 31, 2009. ALJ denied benefits; district court reversed and remanded for a consultative exam; Commissioner appealed.
- Medical record: 1998 knee arthroscopy with release to work without restrictions in 2000; no knee treatment or complaints between 2001 and Mar 31, 2009; limited primary-care visits in 2007–2008 reporting normal gait and denying musculoskeletal symptoms.
- Mr. Castle sought knee treatment beginning June 2009 (after insured period) and had knee arthroplasty in Feb 2010; treating physician Dr. Ansari completed an RFC in Mar 2011 based largely on subjective reports.
- ALJ found severe impairments of obesity and knee arthritis but concluded Castle retained an RFC for less-than-full medium work; discredited subjective limitations inconsistent with activities and lack of treatment during the relevant period; gave little weight to Dr. Ansari’s post‑insured opinion.
- District court held the ALJ’s RFC lacked substantial-evidence support and ordered a consultative exam, reasoning the ALJ “played doctor.” The Eleventh Circuit reversed, holding the record was fully developed and the ALJ’s RFC was supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ’s RFC is supported by substantial evidence | ALJ lacked any medical opinion on RFC; RFC unsupported; ALJ improperly "played doctor" | ALJ’s RFC is supported by medical records, claimant’s testimony, and activities; treating physician’s later opinion is after insured date and based on subjective reports | ALJ’s RFC is supported by substantial evidence; district court erred |
| Whether consultative examination was required | ALJ should have ordered consultative exam to develop the record and obtain medical opinion | No consultative exam required because record was sufficient to make an informed decision | No consultative exam required; remand for exam was improper |
| Proper weight to give treating physician’s post‑insured RFC (Dr. Ansari) | Dr. Ansari’s RFC shows disabling limitations | Dr. Ansari’s opinion is dated after date-last-insured and is based on subjective reports; ALJ permissibly afforded it little weight | ALJ properly gave little weight to Dr. Ansari’s 2011 opinion |
| Whether ALJ impermissibly interpreted raw medical data | ALJ exceeded role by interpreting absence of treatment and test results without physician input | ALJ may make commonsense judgments and assess RFC based on all evidence; regulations assign RFC determination to ALJ | ALJ did not "play doctor"; evaluating a straightforward record is within ALJ’s role |
Key Cases Cited
- Wilson v. Barnhart, 284 F.3d 1219 (11th Cir.) (standards for evaluating claimant’s subjective pain testimony)
- Graham v. Bowen, 790 F.2d 1572 (11th Cir.) (standard for review whether substantial evidence supports ALJ)
- Crawford v. Comm'r of Soc. Sec. Admin., 363 F.3d 1155 (11th Cir.) (definition of substantial evidence)
- Ellison v. Barnhart, 355 F.3d 1272 (11th Cir.) (affirming ALJ where evidence supports decision despite contrary preponderance)
- Phillips v. Barnhart, 357 F.3d 1232 (11th Cir.) (treating physician rule and RFC assessment)
- Lewis v. Callahan, 125 F.3d 1436 (11th Cir.) (RFC as assessment based on all relevant evidence)
- Jones v. Apfel, 190 F.3d 1224 (11th Cir.) (five-step sequential evaluation and burdens)
- Dyer v. Barnhart, 395 F.3d 1206 (11th Cir.) (two-part test for pain testimony and credibility considerations)
- Ingram v. Comm’r of Soc. Sec. Admin., 496 F.3d 1253 (11th Cir.) (ALJ not required to order consultative exam if record is sufficient)
- Graham v. Apfel, 129 F.3d 1420 (11th Cir.) (ALJ’s duty to develop full and fair record)
- Manso-Pizarro v. Sec'y of Health & Human Servs., 76 F.3d 15 (1st Cir.) (consultative exam required where medical record is complex and not amenable to lay interpretation)
- Newsome v. Shalala, 8 F.3d 775 (11th Cir.) (jurisdictional rule on sentence four remand)