Juanda K. Adams v. Commissioner, Social Security Administration
586 F. App'x 531
11th Cir.2014Background
- Adams appeals the district court’s affirmation of the ALJ’s denial of SSI benefits.
- ALJ considered two examining physicians’ and two state agency physicians’ opinions in concluding Adams could perform light work.
- ALJ found Adams not disabled and limited to light exertional work based on RFC assessment.
- The ALJ weighed Adams’s neurologist and consulting physician opinions with substantial evidentiary support.
- The court affirmed, holding the ALJ adequately accounted for medical opinions and Adams’s condition as a whole.
- The decision rejected that the neurologist’s overhead-reaching/breaks recommendations or the consulting physician’s opinion on “any job” control the result.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did ALJ properly weigh medical opinions? | Adams argues the two physician opinions were improperly considered. | Agency contends substantial evidence supports the weighting. | Yes; substantial evidence supports weight given. |
| Is Adams’ RFC and light-work determination supported? | Adams disputes the RFC limiting to light work. | Record supports light exertional work. | Yes; substantial evidence supports light work RFC. |
| Did ALJ err regarding neurologist’s opinion? | ALJ ignored neurologist’s limits on reaching/breaks. | ALJ considered the opinion in context of condition. | No error; addressed in context and weight accorded. |
| Was checking consulting physician’s opinion correctly treated? | Adams argues consulting opinion that she cannot work should have more weight. | Other evidence shows ability to perform light work. | No error; opinion appropriately given little weight. |
Key Cases Cited
- Ingram v. Comm’r of Soc. Sec. Admin., 496 F.3d 1253 (11th Cir. 2007) (de novo review of legal conclusions; substantial evidence standard for facts)
- Miles v. Chater, 84 F.3d 1397 (11th Cir. 1996) (substantial evidence standard; agency’s decision affirmed if supported)
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (burden on claimant to prove disability; five-step process)
- Ellison v. Barnhart, 355 F.3d 1272 (11th Cir. 2003) (claimant bears burden; process requirements)
- Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (treating physician’s opinion with weight; good cause needed)
- Sryock v. Heckler, 764 F.2d 834 (11th Cir. 1985) (ALJ may reject physician if contrary evidence exists)
- Sharfarz v. Bowen, 825 F.2d 278 (11th Cir. 1987) (requirement to state weight given to medical opinions)
- Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (ALJ’s decision must enable reviewing court to see medical consideration)