Sheerin v. Commissioner of Social Security, 3:19-cv-00265

Background

Sandra Sheerin applied for DIB and SSI (protective/filing Oct. 2015), alleging disability from April 20, 2015 due to knee problems, arthritis, migraines, hypertension, tinnitus, anxiety, depression, insomnia, and memory loss.
An ALJ held a hearing (Mar. 14, 2018) and issued a decision (May 2, 2018) finding Sheerin not disabled. The Appeals Council denied review, and Sheerin sued in district court.
The ALJ found severe impairments (arthropathies, hypertension, obesity, migraines, depression, anxiety), assessed an RFC for light work with no climbing or hazards, only occasional stooping/crouching/crawling/kneeling, and limited to simple, routine unskilled tasks with no public contact and only occasional coworker collaboration.
Key medical evidence: a Dec. 2017 MRI showing severe medial compartment osteoarthritis, degenerative posterior medial meniscus tear, attenuated/partially torn ACL and effusion; treatment notes showing intermittent high subjective pain reports but many largely normal musculoskeletal and psychiatric exams.
Psychological evaluation by Dr. Darren Kirkendall (Nov. 2015) diagnosed borderline personality disorder, noted symptom exaggeration, and assessed mild-to-marked limitations (marked limits in decisionmaking/relating to others). The ALJ gave significant weight to Dr. Kirkendall overall but rejected his marked limitations as unsupported.
District court affirmed the Commissioner, holding the ALJ’s RFC and reasons for discounting parts of Dr. Kirkendall’s opinion were supported by substantial evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the RFC (light work) is supported by substantial evidence given decline in left knee and Dec. 2017 MRI	Sheerin: ALJ ignored post-denial decline and MRI findings; ALJ did not specify sit/stand/walk durations and therefore RFC unsupported for 6 hrs standing/walking	SSA: ALJ considered MRI and treatment notes; limiting RFC to "light work" incorporates 6 hours standing/walking by regulatory definition	Court: RFC is supported by substantial evidence; ALJ discussed MRI and records and RFC tied to regulatory definition of light work (≈6 hrs standing/walking)
Whether ALJ gave inadequate reasons for rejecting marked limitations and the borderline personality disorder diagnosis in Dr. Kirkendall’s exam	Sheerin: ALJ said she gave significant weight but rejected more limiting parts without adequate explanation and ignored Kirkendall’s borderline personality disorder diagnosis	SSA: ALJ permissibly focused on functional limitations and found Kirkendall’s marked limits inconsistent with mostly normal mental-status/psychiatric exams; diagnosis alone does not mandate work limitations	Court: ALJ provided adequate, supported reasons to discount the marked limitations; diagnosis alone not dispositive; substantial evidence supports the assessment

Key Cases Cited

Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (five-step sequential evaluation framework)
Bowen v. Yuckert, 482 U.S. 137 (1987) (burden shifting at step five)
Doughty v. Apfel, 245 F.3d 1274 (11th Cir. 2001) (substantial-evidence standard for ALJ findings)
Falge v. Apfel, 150 F.3d 1320 (11th Cir. 1998) (definition of substantial evidence)
Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (no rigid requirement to cite every piece of evidence)
Cornelius v. Sullivan, 936 F.2d 1143 (11th Cir. 1991) (review limited to whether decision is reasonable and supported)
Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (court cannot reweigh evidence)
Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (ALJ must state weight given to medical opinions with particularity)
Sharfarz v. Bowen, 825 F.2d 278 (11th Cir. 1987) (nonexamining opinions get little weight when they contradict examining opinions)
Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (diagnosis alone does not establish work-related limitations)