Justia Public Benefits Opinion Summaries

Plaintiff appeals the district court's order affirming the ALJ's denial of his application for supplemental security income (SSI) benefits, pursuant to 42 U.S.C. 1383(c). Plaintiff contends that the ALJ erred by ruling that he could perform a job with level 3 reasoning after finding that his residual functional capacity limited him to simple, routine, and repetitive tasks, and by basing the number of available jobs on unreliable vocational expert testimony.The Eleventh Circuit joined the Fourth, Ninth, and Tenth Circuits and held that there is an apparent conflict between a limitation to simple, routine, and repetitive tasks and the demands of level 3 reasoning. Because the ALJ did not address that apparent conflict—as required by precedent—and because the court cannot say that the error was harmless, the court reversed and remanded for further proceedings. View "Viverette v. Commissioner of Social Security" on Justia Law

Compensatory education is not an automatic remedy for a child-find violation under the Individuals with Disabilities Education Act (IDEA). Compensatory educational services are designed to counteract whatever educational setbacks a child encounters because of IDEA violations—to bring her back where she would have been but for those violations. At minimum, a parent must offer evidence that a procedural violation—like the child-find violation asserted here—caused a substantive educational harm, and that compensatory educational services can remedy that past harm.The Eleventh Circuit concluded that the district court was well within its "broad discretion and equitable authority" when it concluded that plaintiff had not shown that the school board's child-find violation resulted in educational deficits for the child that could be remediated with prospective compensatory relief. Furthermore, because the school began its special education referral process before plaintiff filed suit, she cannot show that she is entitled to attorney's fees. Accordingly, the court affirmed the district court's judgment. View "J.N. v. Jefferson County Board of Education" on Justia Law

The Eleventh Circuit granted the petition for panel rehearing, withdrew its prior opinion, and issued the following opinion.The court concluded that the ALJ gave little or no weight to three pieces of evidence in the record indicating that plaintiff's mental illness prevents him from maintaining a job: (1) the opinions of plaintiff's treating psychiatrist, (2) the opinions of a consulting psychologist who examined plaintiff at the request of the SSA, and (3) plaintiff's own testimony as to the severity of his symptoms. In this case, the ALJ did not articulate adequate reasons for discounting this evidence, which provided support for a finding of disability. Accordingly, the court reversed and remanded to the agency for further proceedings. View "Simon v. Commissioner, Social Security Administration" on Justia Law

The Eleventh Circuit vacated its prior opinion and substituted the following opinion.The court affirmed the district court's decision affirming the agency's finding that plaintiff was ineligible for disability insurance benefits. The court held that there is no apparent conflict between one's limitation to following simple instructions and positions that require the ability to follow "detailed but uninvolved" instructions. The court concluded that the agency's decision was otherwise supported by substantial evidence. View "Buckwalter v. Acting Commissioner of Social Security" on Justia Law

The Eleventh Circuit reversed and remanded the denial of social security disability benefits to plaintiff, who stated that he was no longer able to work due to various psychiatric conditions, which included chronic depression, anxiety, and bipolar disorder. The court held that the SSA's denial of plaintiff's application for disability benefits was not supported by substantial evidence where the ALJ did not articulate adequate reasons for discounting evidence of plaintiff's mental illness, which provided support for a finding of disability. In this case, the ALJ gave little or no weight to three pieces of evidence in the record indicating that plaintiff's mental illness prevents him from maintaining a job: (1) the opinions of plaintiff's treating psychiatrist, (2) the opinions of a consulting psychologist who examined plaintiff at the request of the SSA, and (3) plaintiff's own testimony as to the severity of his symptoms. View "Simon v. Commissioner, Social Security Administration" on Justia Law

The Eleventh Circuit affirmed the Commissioner's denial of plaintiff's application for disability insurance benefits pursuant to 42 U.S.C. 405(g). The court held that there is no apparent conflict between one's limitation to following simple instructions and positions that require the ability to follow "detailed but uninvolved" instructions. The court concluded that the decision to deny benefits is otherwise supported by substantial evidence. View "Buckwalter v. Acting Commissioner of Social Security" on Justia Law

The Eleventh Circuit affirmed the district court's decision affirming the ALJ's denial of social security disability benefits, holding that substantial evidence supports the ALJ's decision that plaintiff is not disabled. In this case, the ALJ assigned little weight to the opinions of a physician and a vocational rehabilitation specialist where the ALJ correctly understood that their statements were not dispositive. Furthermore, a vocational rehabilitation specialist is not a treating physician, and thus his opinion is not entitled to substantial or considerable weight, and the physician's opinion that plaintiff would be "permanently and totally disabled" conflicted with his own examinations of plaintiff, which showed no significant abnormalities. Finally, the court rejected plaintiff's argument under Bjornson v. Astrue, 671 F.3d 640, 647–48 (7th Cir. 2012). View "Walker v. Social Security Administration" on Justia Law

The Eleventh Circuit vacated the district court's order affirming the denial of plaintiff's application for benefits under the Social Security Act. The court agreed with plaintiff that substantial evidence does not support the ALJ's finding that plaintiff could perform a job that exists in significant numbers in the national economy. The court held that the vocational expert's testimony as to available jobs, on which the ALJ relied, was significantly and admittedly flawed.In this case, the vocational expert used the wrong Standard Occupational Classification (SOC) group code to determine whether there are a significant number of jobs in the national economy that plaintiff could perform. Furthermore, even if the court overlooked this foundational problem, the numbers that the vocational expert cited from the wrong SOC group code substantially overstated the number of available bakery worker jobs that plaintiff could perform. Accordingly, the court remanded for further proceedings. View "Goode v. Commissioner of Social Security" on Justia Law

The Eleventh Circuit affirmed the denial of social security disability benefits to plaintiff. The court rejected plaintiff's claim that the ALJ erred in finding that plaintiff was not disabled because the ALJ failed to appropriately consider the VA's determination that plaintiff was unable to work due to a disability and thus entitled to veterans' benefits. Rather, the court held that the ALJ's decisions demonstrates that he considered the VA's determination. The court also held that substantial evidence, including recent medical records that postdate the VA's decision, supported the ALJ's rejection of the VA's disability decision as determinative of whether plaintiff was disabled for Social Security purposes. View "Noble v. Commissioner of Social Security" on Justia Law

The Eleventh Circuit vacated the district court's order affirming the Commissioner's denial of plaintiff's application for disability insurance benefits. The court held that the ALJ did not have the benefit of the court's decision in Schink v. Comm'r of Soc. Sec., 935 F.3d 1245 (11th Cir. 2019) (per curiam), which may alter the fourth step of the ALJ's disability analysis. Furthermore, the court agreed with plaintiff that the ALJ's hypothetical to the vocational expert did not sufficiently communicate plaintiff's limitations from bipolar disorder. View "Samuels v. Acting Commissioner of Social Security" on Justia Law