Zinta Harner v. Social Security Administration, Commissioner, 38 F.4th 892

Harner applied for Social Security disability benefits in April 2017, alleging spine disorders, fibromyalgia, migraines, fatigue, asthma, and related limitations.
Treating providers (rheumatologist Chindalore, neurosurgeon Johnson, NP Pettry) opined Harner could sit/stand <2 hours/day and was disabled as of August 5, 2016.
The ALJ held a 2019 hearing, reviewed medical records, heard testimony from Harner and a vocational expert, and found Harner had the RFC for light work with some restrictions.
The ALJ declined to give treating opinions controlling weight and evaluated medical opinions under 20 C.F.R. § 404.1520c, finding the treating opinions unpersuasive and state-agency opinions persuasive.
The Appeals Council denied review; the district court affirmed. On appeal, the Eleventh Circuit considered whether § 404.1520c validly abrogated the treating-physician rule and whether it applied to Harner’s claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of 20 C.F.R. § 404.1520c (did it lawfully replace the treating-physician rule?)	Harner contends prior Eleventh Circuit treating-physician precedent remains controlling.	Commissioner argues § 404.1520c is within delegated authority and rationally replaces the rule.	Regulation is within authority and not arbitrary or capricious; it validly abrogates the treating-physician rule.
Whether § 404.1520c applies to Harner’s claim and whether the ALJ erred by not giving treating physicians deference	Harner argues the ALJ should have applied the treating-physician rule/deferred to treating opinions.	Commissioner/ALJ applied § 404.1520c (claims filed after Mar. 27, 2017) and evaluated opinions for persuasiveness rather than giving controlling weight.	§ 404.1520c applies (claim filed Apr. 28, 2017); ALJ did not err by declining to give treating-source controlling weight.
Other challenges (substantial evidence, fibromyalgia analysis, daily activities)	Harner raises additional attacks on ALJ findings and evidence weighing.	Agency contends issues are inadequately briefed.	Court finds Harner forfeited these arguments for lack of developed briefing; affirmance stands.

Heckler v. Campbell, 461 U.S. 458 (U.S. 1983) (agency regulations implementing Social Security provisions entitled to deference when within statutory authority)
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (U.S. 1984) (framework for judicial deference to reasonable agency interpretations)
National Cable & Telecommunications Ass'n v. Brand X Internet Services, 545 U.S. 967 (U.S. 2005) (agency interpretations can displace prior judicial constructions unless the statute is unambiguous)
Black & Decker Disability Plan v. Nord, 538 U.S. 822 (U.S. 2003) (discussing the treating-physician rule and agency regulation history)
Walden v. Schweiker, 672 F.2d 835 (11th Cir. 1982) (Eleventh Circuit decision adopting the treating-physician rule)
Doughty v. Apfel, 245 F.3d 1274 (11th Cir. 2001) (procedural note on when an ALJ decision becomes final agency action)
Buckwalter v. Acting Comm'r of Soc. Sec., 5 F.4th 1315 (11th Cir. 2021) (standard of review: ALJ’s legal conclusions reviewed de novo)
Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014) (issues inadequately briefed are forfeited)