482 F. App'x 483
11th Cir.2012Background
- Beegle appeals the ALJ’s denial of disability insurance benefits under Titles II and XVIII.
- The ALJ found Beegle had severe physical impairments (osteoarthritis in the right knee and carpal tunnel) but not a severe mental impairment due to depression.
- Standard of review applied is substantial evidence within the five-step SSA framework; claimant bears the burden of proving disability.
- The ALJ weighed medical opinions, giving Dr. Storjohann’s opinion little weight while relying on treating sources where appropriate and on non-treating opinions where warranted.
- The ALJ concluded Beegle could perform a significant number of jobs in the national economy, based on a vocational expert’s testimony and Beegle’s residual functional capacity.
- Beegle argues errors related to mental impairment assessment, reliance on medical opinions, treatment history, and hypothetical questions; the court affirms substantial evidence supporting the decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Beegle suffered a severe mental impairment. | Beegle argues depression is severe. | ALJ found only mild limitations, no severe impairment. | Affirmed: no severe mental impairment. |
| Whether there exist a significant number of jobs Beegle can perform. | Challenges ALJ’s reliance on Dr. Jin and hypothetical to VN. | ALJ properly weighed opinions and posed adequate hypotheticals. | Affirmed: significant jobs exist. |
| Whether the ALJ properly weighed Dr. Storjohann’s opinion. | ALJ substituted her own medical judgment overruling Storjohann. | Single-examiner opinion not controlling; ALJ properly weighed record. | Affirmed: substantial evidence supports weight assigned. |
| Whether the ALJ adequately explained weight given to medical opinions. | ALJ did not sufficiently justify discounting Storjohann. | ALJ provided reasons supported by record findings and testimony. | Affirmed: explanation adequate. |
| Whether the hypothetical questions to the vocational expert were complete. | Hypotheticals failed to account for knee pain and other limitations. | Hypotheticals implicitly accounted for limitations and relied on Dr. Smith and Beegle’s record. | Affirmed: complete and supported. |
Key Cases Cited
- Winschel v. Comm’r of Soc. Sec.,, 631 F.3d 1176 (11th Cir. 2011) (substantial evidence standard and review framework)
- Ellison v. Barnhart,, 355 F.3d 1272 (11th Cir. 2003) (claimant bears burden; noncompliance considerations)
- McSwain v. Bowen,, 814 F.2d 617 (11th Cir. 1987) (treating physician not always controlling when not a treating source)
- Sryock v. Heckler,, 764 F.2d 834 (11th Cir. 1985) (ALJ may reject medical opinions with contrary evidence)
- Graham v. Bowen,, 790 F.2d 1572 (11th Cir. 1986) (hypotheticals need not include every limitation if unsupported by record)
- Crawford v. Comm’r of Soc. Sec.,, 363 F.3d 1155 (11th Cir. 2004) (hypothetical must reflect supported record limitations)
- Wilson v. Barnhart,, 284 F.3d 1219 (11th Cir. 2002) (vocational expert testimony relies on accurate hypotheticals)
- Jones v. Apfel,, 190 F.3d 1224 (11th Cir. 1999) (burden-shifting at step five considerations)