May v. Commissioner of Social Security
3:24-cv-00343
M.D. Fla.Apr 14, 2025Background
- Venetia May filed for Social Security disability and disability insurance benefits, alleging disability from January 29, 2021.
- Claim was denied at both initial and reconsideration stages; ALJ also denied benefits after a hearing.
- ALJ found May had severe impairments (spine disorders, major joint abnormalities) but retained the residual functional capacity (RFC) for light work with some limitations.
- May challenged the ALJ’s RFC assessment, focusing on insufficient consideration of her cubital tunnel syndrome, anxiety, and her inability to afford medical care.
- The District Court reviewed whether the ALJ's decision was supported by substantial evidence and applied the correct legal standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFC Assessment (Physical Impairment) | ALJ failed to consider full limiting effects of right-side cubital tunnel syndrome in the RFC. | ALJ did consider the syndrome, evidence, and limited RFC accordingly; no further limitations warranted. | ALJ considered cubital tunnel syndrome appropriately; decision was supported by substantial evidence. |
| RFC Assessment (Mental Impairment) | ALJ should have included mental RFC limitations due to anxiety, especially given skilled prior work. | Anxiety found to cause only mild limitations; no need for RFC limitations on that basis. | ALJ’s finding of mild impairment supported by evidence; no further RFC limitations required. |
| Vocational Expert Hypotheticals | ALJ’s hypothetical omitted handling/fingering limitations, leading to error in past work finding. | Hypotheticals included all limitations supported by the record as found by ALJ. | ALJ was not required to include unsupported limitations; hypothetical sufficed. |
| Lack of Treatment Due to Finances | ALJ improperly considered lack of treatment where May couldn’t afford care or lacked insurance. | Decision was not based solely on treatment gaps; medical and other evidence supported denial. | ALJ did not deny benefits solely due to treatment gaps; no error. |
Key Cases Cited
- Crawford v. Comm'r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (substantial evidence review standard for SSA appeals)
- Winschel v. Comm'r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (hypothetical questions to vocational experts must include all impairments)
- Keeton v. Dep’t of Health & Human Servs., 21 F.3d 1064 (11th Cir. 1994) (failure to apply correct legal standard requires reversal)
- Foote v. Chater, 67 F.3d 1553 (11th Cir. 1995) (court cannot reweigh evidence; must affirm if supported by substantial evidence)
- Martin v. Sullivan, 894 F.2d 1520 (11th Cir. 1990) (standard for reviewing SSA factual findings)