Middleton v. Social Security Administration, Commissioner, 1:10-cv-02918

Middleton filed a claim for disability benefits under 42 U.S.C. § 405(g) challenging the SSA Commissioner’s decision.
The case was reviewed by the Northern District of Alabama, Eastern Division, with the court applying the substantial evidence standard.
The ALJ’s decision denied benefits, prompting Middleton to seek judicial review in district court.
Middleton alleges the ALJ improperly weighed treating and examining medical evidence and erred in evaluating her credibility.
The court finds merit in Middleton’s challenge to the ALJ’s consideration of the treating psychiatrist Dr. Castro’s March 4, 2008 assessment.
The case is remanded to the SSA for further proceedings consistent with the memorandum opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly weighed treating psychiatrist opinion	Middleton argues Castro’s March 4, 2008 assessment warrants substantial weight.	The Commissioner contends the ALJ reasonably weighed the evidence.	Remand for reevaluation of treating-source opinion
Whether the ALJ erred by not addressing Castro's March 4, 2008 assessment	ALJ failed to address a controlling treating opinion.	The ALJ's decision stands despite not expressly addressing every piece of evidence.	Remand warranted for proper consideration of Castro's findings

Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (treating physician's opinion entitled substantial weight absent good cause)
Lamb v. Bowen, 847 F.2d 698 (11th Cir. 1988) (scope of review limited to substantial evidence and correct law)
Tieniber v. Heckler, 720 F.2d 1251 (11th Cir. 1983) (application of substantial evidence standard)
Wheeler v. Heckler, 784 F.2d 1073 (11th Cir. 1986) (weight of physician statements depends on support by clinical findings)