Rhonda Lynn Nichols v. Commissioner, Social Security Administrations
679 F. App'x 792
11th Cir.2017Background
- Nichols applied for disability insurance benefits and SSI after a work-related fall in October 2009; ALJ denied benefits and Appeals Council declined review.
- ALJ found severe impairments: degenerative lumbar disc disease (spondylosis/stenosis, scoliosis), obesity, depressive disorder, and possible borderline intellectual functioning.
- ALJ concluded Nichols could not perform her past medium-level jobs but retained the RFC for a range of light, unskilled work (cleaner, housekeeper, sorter).
- Nichols produced a 2013 consultative WAIS with a full-scale IQ of 59 but the ALJ found the scores invalid or inconsistent with her adaptive functioning and daily activities.
- Treating orthopedist Dr. Prevost expressed conflicting views (released her to light/full duty, later suggested disability); the ALJ gave his opinion limited weight based on inconsistency with his own treatment records and the broader record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Nichols meets Listing 12.05(B) or (C) for intellectual disability | Nichols: IQ scores (FSIQ 59) satisfy Listing 12.05(B)/(C) | Commissioner: IQ scores invalid or inconsistent with record and adaptive functioning | Court: Affirmed ALJ — scores properly discounted; Listing not met |
| Whether ALJ failed to evaluate impairments in combination | Nichols: ALJ did not adequately consider combined effects of mental and physical impairments | Commissioner: ALJ expressly considered all impairments in combination and discussed whole record | Court: Affirmed — ALJ considered combined impairments |
| Whether back impairment alone rendered Nichols disabled | Nichols: Dr. Prevost’s opinion that back pain prevents work requires disability finding | Commissioner: Record evidence and other physicians contradict an across-the-board disabling limitation | Court: Affirmed — substantial evidence supports RFC for light work with limitations |
| Whether ALJ improperly weighed treating physician Prevost’s opinion | Nichols: ALJ should have given controlling weight to treating physician | Commissioner: ALJ gave reasons (inconsistency, treatment course, other evidence) amounting to good cause to give less weight | Court: Affirmed — ALJ articulated good cause and supported weight assignment |
Key Cases Cited
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (claimant bears burden to prove disability; standard of review).
- Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (ALJ must weigh medical opinions and may reject treating opinion for good cause).
- Sullivan v. Zebley, 493 U.S. 521 (U.S. 1990) (to meet a Listing, claimant must satisfy all specified medical criteria).
- Hodges v. Barnhart, 276 F.3d 1265 (11th Cir. 2001) (IQ scores after age 22 create rebuttable presumption of lifelong IQ).
- Lowery v. Sullivan, 979 F.2d 835 (11th Cir. 1992) (IQ scores inconsistent with evidence of daily functioning may be rejected).
- Popp v. Heckler, 779 F.2d 1497 (11th Cir. 1986) (ALJ may find IQ test results incredible if inconsistent with record).
- Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (treating physician’s opinion entitled to substantial weight absent good cause).
- Lewis v. Callahan, 125 F.3d 1436 (11th Cir. 1997) (ALJ must clearly articulate reasons for discounting treating physician opinion).