Kanella Karen Hantzis v. Commissioner of Social Security
686 F. App'x 634
| 11th Cir. | 2017Background
- Kanella Hantzis applied in 2009 for disability insurance benefits based on chronic back/leg pain (stemming from two 1989 falls), vertigo, degenerative disc disease, and hip dysfunction, with an alleged onset of July 1, 1993.
- An ALJ held a 2011 hearing with Hantzis and a vocational expert, then denied benefits, finding she had severe impairments but retained the RFC for a full range of light work and could perform past relevant work or other jobs in the economy.
- The Appeals Council declined review, so the ALJ’s decision became the Commissioner’s final decision under 42 U.S.C. § 405(g).
- On appeal pro se, Hantzis argued the ALJ improperly discounted functional limitations assessed by long‑time treating physicians Drs. Robert Ho and Mark Brennan (limitations on sitting, standing, bending, twisting), though the ALJ gave partial weight to a 20‑pound lifting restriction.
- The ALJ explained he discounted those treating‑physician restrictions because they were not supported by the doctors’ own records, were inconsistent with the overall record (improvement with conservative treatment, objective testing generally normal), and the ultimate disability determination is reserved to the Commissioner.
- The Eleventh Circuit affirmed, holding the ALJ applied correct legal standards, gave adequate reasons (good cause) for discounting the treating‑physician opinions, and that substantial evidence supports the decision; two other issues raised below were abandoned on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ erred in weighing treating physicians’ opinions about functional limits (sit/stand/bend/twist) | Hantzis: ALJ should have given controlling/substantial weight to Drs. Ho and Brennan’s long‑term treating opinions limiting sitting, standing, bending, twisting | Commissioner/ALJ: ALJ permissibly gave little weight to those restrictions because they were unsupported by the doctors’ own notes and inconsistent with the longitudinal record and objective tests; he gave significant weight to the 20‑lb lifting limit | Court: Affirmed — ALJ applied correct legal standard, articulated good cause for discounting those opinions, and substantial evidence supports the RFC finding |
| Alleged errors not raised on appeal (retrospective 2009 opinion; RFC/hypothetical omission of vertigo and migraines) | Hantzis argued below these errors existed | Commissioner: These issues were not raised on appeal | Court: Abandoned on appeal; not addressed |
Key Cases Cited
- Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (ALJ must assess RFC considering all relevant evidence)
- Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (treating physician’s opinion must be given substantial weight unless good cause shown)
- Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (examples of good cause to discount treating opinions)
- Doughty v. Apfel, 245 F.3d 1274 (11th Cir. 2001) (Appeals Council review and finality of Commissioner decision)
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (ALJ’s supported articulation of reasons avoids reversible error)
- Sryock v. Heckler, 764 F.2d 834 (11th Cir. 1985) (ALJ may reject medical opinion if evidence supports contrary finding)
- Lewis v. Callahan, 125 F.3d 1436 (11th Cir. 1997) (ALJ must clearly articulate reasons for giving less weight to treating opinions)
- Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014) (issues not raised on appeal are abandoned)
