Winschel v. Commissioner of Social Security
631 F.3d 1176
| 11th Cir. | 2011Background
- Winschel appeals the district court's affirmation of the ALJ's denial of disability benefits and SSI.
- Winschel argues the ALJ failed to specify the weight given to treating and examining physicians' medical opinions.
- Winschel argues the ALJ posed an incomplete hypothetical to the vocational expert and relied on it to find substantial jobs exist.
- The Eleventh Circuit reverses and remands for explicit consideration of medical opinions and for a proper hypothetical.
- The court explains substantial evidence requires clear articulation of weights and grounds for discounting medical opinions.
- At issue is whether the ALJ properly integrated concentration, persistence, and pace limitations into the step-five analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight of medical opinions | Winschel contends the ALJ failed to weight treating and examining opinions. | Commissioner argues treating notes are not medical opinions requiring weight. | Remand; ALJ must explicitly weigh and explain grounds for medical opinions. |
| Hypothetical to vocational expert | ALJ's hypo did not account for moderate concentration/persistence/pace limitations. | VE testimony can support step-five findings if hypo accounts for impairments. | Remand; include explicit moderate limitation in concentration, persistence, and pace in the hypo. |
Key Cases Cited
- Crawford v. Comm'r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (substantial evidence and legal standards standard explained)
- Lewis v. Callahan, 125 F.3d 1436 (11th Cir. 1997) (substantial evidence requirement)
- Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (five-step framework and RFC context)
- Sharfarz v. Bowen, 825 F.2d 278 (11th Cir. 1987) (need for precise articulation of medical opinion weight)
- Cowart v. Schweiker, 662 F.2d 731 (11th Cir. 1981) (district court must scrutinize ALJ's grounds)
- Owens v. Heckler, 748 F.2d 1511 (11th Cir. 1984) (vacant grounds require remand when not articulated)
- Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005) (PRT must be integrated into findings)
- Ramirez v. Barnhart, 372 F.3d 546 (3d Cir. 2004) (PRT findings role in steps four and five)
- Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002) (hypothetical must reflect claimant's impairments)