Summary
The United States District Court for the Southern District of Alabama reviewed the Commissioner of Social Security’s denial of Robert A. Snodgrass’s claim for Disability Insurance Benefits. The court held that the Administrative Law Judge properly evaluated the medical opinions, adequately supported the residual functional capacity determination, and affirmed the Commissioner’s decision.
Holdings
- The ALJ adequately addressed Dr. Shenesey's opinion by finding its stated limitations supported by the examination, explaining that the limitations were not expressed in quantifiable vocational terms, and incorporating verifiable limitations into the RFC. Any failure to expressly label the opinion's overall persuasiveness was harmless.
- The ALJ properly evaluated Dr. Kopp's opinion, including its consistency with other medical and nonmedical evidence, and adequately supported the conclusion that the opinion was unpersuasive.
- The Commissioner's decision denying Snodgrass Disability Insurance Benefits was supported by substantial evidence and based on proper legal standards.
Questions Presented
- Whether the ALJ properly evaluated the persuasiveness of Dr. Jessica Shenesey's medical opinion after the Appeals Council remanded for consideration of that opinion.
- Whether the ALJ properly evaluated the consistency of Dr. Kopp's medical opinion with the other medical and nonmedical evidence after remand.
- Whether the ALJ's residual functional capacity determination and resulting denial of Disability Insurance Benefits were supported by substantial evidence and based on proper legal standards.
Disposition
affirmed
Cases Cited (11)
- Moore v. Barnhart, 405 F.3d 1208, 1211 (11th Cir. 2005)(followed)
- Watkins v. Comm’r of Soc. Sec., 457 F. App’x 868, 870 (11th Cir. 2012) (per curiam)(followed)
- Phillips v. Barnhart, 357 F.3d 1232, 1237 (11th Cir. 2004)(followed)
- Jones v. Apfel, 190 F.3d 1224, 1228 (11th Cir. 1999)(followed)
- Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011)(followed)
- Chester v. Bowen, 792 F.2d 129, 131 (11th Cir. 1986)(followed)
- MacGregor v. Bowen, 786 F.2d 1050, 1053 (11th Cir. 1986)(followed)
- Green v. Soc. Sec. Admin., 223 F. App’x 915, 923 (11th Cir. 2007)(followed)
- Pritchett v. Colvin, Civ. A. No. 12-0768-M, 2013 WL 3894960, at *5 (S.D. Ala. July 29, 2013)(followed)
- Jones v. Colvin, CA 14-00247-C, 2015 WL 5737156, at *23 (S.D. Ala. Sept. 30, 2015)(followed)
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Cited In (0)
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Court Document
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