Reba Williams v. Commissioner, Social Security Administration
703 F. App'x 780
| 11th Cir. | 2017Background
- Reba Williams applied for Social Security disability insurance benefits in May 2012, alleging onset August 31, 2009 (after back surgery); insured through December 31, 2010.
- ALJ found severe impairments: diffuse osteoarthritis, status post cervical and lumbar surgeries, and spinal disc bulges; anxiety/depression and diverticulosis deemed nonsevere.
- ALJ assessed RFC for light work with limitations and concluded Williams could perform her past relevant work, denying benefits for the period up to the date last insured.
- ALJ gave "little weight" to treating surgeon Dr. Clark Metzger’s post‑surgery restrictions (no bending/stooping/lifting >10 lbs), finding them recovery‑related and inconsistent with later MRIs and Williams’s reported activities.
- Williams submitted additional medical records to the Appeals Council; the Council considered and added them to the record but denied review as they did not warrant changing the ALJ’s decision.
- District court affirmed; Williams appealed. The appellate court reviewed for substantial evidence and proper legal standards and affirmed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Appeals Council failed to consider additional evidence | Appeals Council ignored pre‑DLI records or failed to meaningfully consider new evidence | Appeals Council stated it considered and added the evidence and found it did not change the ALJ’s decision | Appeals Council adequately considered the additional evidence and permissibly denied review |
| Whether ALJ failed to develop the record (Mizell Hospital records) | ALJ did not obtain all pre‑onset medical records | ALJ requested and received Mizell records (June 2008–Nov 2010); claimant’s counsel confirmed the record was complete at hearing | ALJ satisfied the duty to develop a full and fair record |
| Whether additional evidence undermines substantial evidence supporting the ALJ | New evidence is material and changes the disability analysis | Additional records are cumulative, not chronologically relevant, or not material | Additional evidence does not undermine substantial evidence supporting ALJ’s decision |
| Whether ALJ improperly discounted treating physician’s opinion (Dr. Metzger) | ALJ substituted his lay judgment for treating physician and failed to give proper weight | ALJ gave reasons: opinion was post‑operative recovery advice, inconsistent with later MRIs and claimant’s activities; good cause to discount | ALJ had good cause and properly articulated reasons to give Dr. Metzger’s opinion little weight |
| Whether Williams can perform past relevant work | Williams cannot perform past work due to limitations | ALJ’s RFC supported ability to perform past work; burden on claimant to prove inability | Claimant failed to point to record evidence; ALJ’s finding supported by substantial evidence |
Key Cases Cited
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (standard of review for Commissioner’s decision)
- Lewis v. Callahan, 125 F.3d 1436 (11th Cir. 1997) (definition of substantial evidence)
- Mitchell v. Comm’r, Soc. Sec. Admin., 771 F.3d 780 (11th Cir. 2014) (Appeals Council consideration of new evidence)
- Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (good cause to discount treating physician opinion)
- Ellison v. Barnhart, 355 F.3d 1272 (11th Cir. 2003) (ALJ duty to develop medical record)
- Hyde v. Bowen, 823 F.2d 456 (11th Cir. 1987) (materiality and relevance of additional evidence)
- Lucas v. Sullivan, 918 F.2d 1567 (11th Cir. 1990) (claimant’s burden to show inability to perform past work)