Walden v. Social Security Administration, Commissioner, 4:10-cv-01166

Connie Walden, 48, sues to reverse the Commissioner’s denial of DIB after administrative proceedings.
ALJ found Walden not disabled and insured through the date of decision, with a period of disability for DIB purposes.
Impairments identified as pulmonary hypertension, left bundle branch block, and left upper-extremity neuropathy; found severe but not equal to listed impairments.
Walden’s residual functional capacity limited to sedentary work with specific lifting, standing/walking, sitting, and pushing/pulling constraints; past work deemed not transferable.
ALJ relied on a 2008 RFC assessment and rejected Dr. Lee’s treating opinions as not fully supported by the record.
Walden challenged treating-physician weighting, subjective-pain credibility, VE hypotheticals, and requests to remand for new evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Treating-physician weight	Walden argues Dr. Lee’s opinion should receive more weight.	Walden contends Lee’s findings are inconsistent with the record; the ALJ properly gave little weight.	ALJ gave good cause for reduction and substantial evidence supports it.
Subjective pain credibility	Walden claims the ALJ erred in discrediting her pain testimony.	ALJ properly considered medical evidence, daily activities, medication use, and inconsistencies.	ALJ’s credibility assessment supported by substantial evidence.
Hypothetical to VE	Hypotheticals omitted Walden’s pain/weakness and regular absences.	Hypotheticals properly reflected record-supported findings; not required to include every symptom.	Hypotheticals were complete and supported by the record; no remand for VE error.
Motions to remand for new evidence	Motion to remand for nurse-practitioner questionnaire and for a subsequent favorable ALJ decision.	New evidence is immaterial or not properly admissible to change outcome; HALLEX cited but not controlling.	Remand denied; new evidence not material and not proper to compel reconsideration.

Crawford v. Commissioner of Social Security, 363 F.3d 1155 (11th Cir. 2004) (treating-source opinions and disability determinations require proper weight and credibility analysis)
Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002) (credibility evaluation and articulation of reasons for discounting symptoms)
Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (pain standard and reliance on medical evidence when assessing credibility)
Jones v. Apfel, 190 F.3d 1224 (11th Cir. 1999) (requirement that hypotheticals include all impairments supported by record)
Ingram v. Commissioner of Social Security, 496 F.3d 1253 (11th Cir. 2007) (ALJ not obligated to include every symptom in hypotheticals)
Caulder v. Bowen, 791 F.2d 872 (11th Cir. 1986) (remand standards for new evidence; good cause requirement)