Young v. Commissioner of Social Security, 3:15-cv-00277

Plaintiff Kim Young applied for disability insurance benefits alleging onset Jan 1, 2011; applications were denied and an ALJ found her not disabled through the date last insured (June 30, 2013).
Severe impairments found by the ALJ: degenerative joint/disc disease, affective mood disorder, obesity, ADHD, and anxiety.
ALJ assessed an RFC for a restricted range of light work with limitations to occasional lower-left extremity use, limited posturals, short/simple routine tasks, moderate limits on detailed instructions and prolonged concentration, and limited public interaction.
Treating psychiatrist Thomas Wikstrom, M.D., completed a May 30, 2013 mental health questionnaire opining marked/extreme functional limits, inability to work, and more than four absences per month, with onset as of December 2010.
ALJ gave little weight to Dr. Wikstrom’s questionnaire, finding it inconsistent with his treatment notes and unsupported by the objective record; ALJ credited state agency and consultative opinions that showed only moderate limitations.
With vocational expert testimony, the ALJ identified representative jobs (gate attendant, mail clerk, cleaner) and concluded Plaintiff was not disabled; the district court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ erred in discounting treating psychiatrist Dr. Wikstrom’s opinions	ALJ lacked "good cause" to give little weight to the May 2013 questionnaire; opinions should receive substantial/treating weight	ALJ articulated valid, supported reasons: questionnaire inconsistent with longitudinal treatment notes and other objective evidence	Court held ALJ had good cause; reasons supported by substantial evidence and affirmed the denial

McRoberts v. Bowen, 841 F.2d 1077 (11th Cir. 1988) (scope of district court review of Social Security decisions)
Richardson v. Perales, 402 U.S. 389 (Supreme Court) (substantial evidence standard)
Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (definition of substantial evidence)
Edwards v. Sullivan, 937 F.2d 580 (11th Cir. 1991) (affirmance where substantial evidence supports Commissioner despite contrary evidence)
Barnes v. Sullivan, 932 F.2d 1356 (11th Cir. 1991) (same)
Foote v. Chater, 67 F.3d 1553 (11th Cir. 1995) (court must consider the record as a whole)
Lowery v. Sullivan, 979 F.2d 835 (11th Cir. 1992) (entire record scrutiny required)
Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176 (11th Cir. 2011) (ALJ must state with particularity weight given to medical opinions)
Lewis v. Callahan, 125 F.3d 1436 (11th Cir. 1997) (treating physician rule: give substantial weight absent good cause)
Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (defining "good cause" to discount treating physician)
Marbury v. Sullivan, 957 F.2d 837 (11th Cir. 1992) (ALJ must clearly articulate reasons for rejecting treating physician opinion)