William P. Wiggins v. Richard S. Schweiker, Secretary of the Department of Health and Human Services

Summary

The Eleventh Circuit reversed and remanded a denial of Social Security disability benefits. The court held that the administrative law judge failed to show whether appropriate weight was given to the treating physician's evidence and applied an incorrect standard by requiring objective medical support for subjective complaints of pain. The court also directed consideration of the combined effects of the claimant's impairments.

Holdings

1. An ALJ must accord substantial or considerable weight to the opinion, diagnosis, and medical evidence of a claimant's treating physician unless good cause is shown to the contrary, and the ALJ must explain the weight given or the good cause for discounting that evidence.
2. An ALJ may not reject or disregard a claimant's subjective complaints of pain simply because they are unsupported by objective clinical or laboratory findings, when the pain is linked to a medically determinable impairment.
3. An ALJ must consider the combined disabling effect of all of a claimant's impairments, although the court did not decide whether the ALJ in this case had in fact failed to do so.

Questions Presented

1. Whether the ALJ failed to apply the required legal standard in evaluating the opinion and medical evidence of Wiggins's treating physician.
2. Whether the ALJ applied an erroneous legal standard by requiring subjective complaints of pain to be supported by objective clinical or laboratory findings.
3. Whether the ALJ was required to consider the combined disabling effect of Wiggins's impairments.

Disposition

reversed_and_remanded