Crawford v. Commissioner of Social Security
363 F.3d 1155 (2004)
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Rule of Law:
An Administrative Law Judge (ALJ) may discount a treating physician's opinion for 'good cause,' which exists if the opinion is conclusory, unsupported by objective medical evidence, or contradicted by the physician's own treatment notes.
Facts:
- Billy D. Crawford, a 53-year-old male, alleged he became disabled on March 1, 1999, due to conditions including bilateral spondylolysis and degenerative disc disease.
- Crawford's treating physicians, Drs. Zemankiewicz, Ruiz, and Blavatsky, as well as his chiropractor, Mabbett Reckord, provided opinions that he was 'disabled' or had functional limitations precluding even sedentary work.
- Dr. Ruiz's treatment notes showed that only three weeks after concluding Crawford was permanently disabled, he noted Crawford was 'improved,' 'doing well,' and that further tests revealed no musculoskeletal abnormalities.
- An MRI reviewed by Dr. Zemankiewicz revealed only 'very minimal degenerative disc disease' with 'no bulge or protrusion' and 'no canal stenosis or nerve root impingement.'
- Dr. Blavatsky's treatment notes indicated that Crawford's MRI and bone scan were negative and showed 'no evidence of spondylolisthesis.'
- Consultative psychologist Tracy Hartig examined Crawford once and concluded he had 'marked' psychological limitations.
- Treating psychiatrist J.K. Mehta examined Crawford on two occasions and reported his mood was 'feeling better' and suggested vocational rehabilitation.
Procedural Posture:
- Billy D. Crawford applied for disability insurance benefits and supplemental social security income.
- The Social Security Administration denied his applications initially and on reconsideration.
- Crawford requested and received a hearing before an Administrative Law Judge (ALJ), who found he was not disabled and denied his claim.
- The Social Security Appeals Council denied Crawford's request for review.
- Crawford filed a lawsuit in the U.S. District Court seeking judicial review of the Commissioner's decision.
- A magistrate judge issued a report recommending that the Commissioner's decision be affirmed.
- The district court adopted the magistrate's recommendation and entered an order affirming the Commissioner's denial of benefits.
- Crawford (appellant) appealed the district court's order to the U.S. Court of Appeals for the Eleventh Circuit, with the Commissioner of Social Security as the appellee.
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Issue:
Does an Administrative Law Judge (ALJ) err by discrediting the opinions of a claimant's treating physicians and a consultative psychologist when those opinions are internally inconsistent and contradicted by objective medical evidence in the record?
Opinions:
Majority - Per Curiam
No. An ALJ does not err by discrediting treating physicians' opinions when there is 'good cause' to do so. The court found that substantial evidence supported the ALJ's decision. A treating physician's opinion must be given substantial weight unless 'good cause' to the contrary is shown. Good cause exists when a physician's opinion is conclusory, not accompanied by objective medical evidence, or is contradicted by the physician's own treatment notes. In this case, the opinions of Drs. Ruiz, Blavatsky, and Zemankiewicz were all inconsistent with their own contemporaneous notes and objective findings from MRIs and other tests. The chiropractor's opinion was properly discounted as he is not an 'acceptable medical source' under regulations, and his notes were also internally inconsistent. Finally, the consultative psychologist's opinion was properly given less weight because she was not a treating source (having seen Crawford only once) and her findings were contradicted by the treating psychiatrist.
Analysis:
This decision reinforces the 'good cause' standard, granting ALJs significant deference in weighing conflicting medical evidence in Social Security disability cases. It clarifies that internal contradictions within a physician's own records constitute strong evidence of 'good cause' for discounting that physician's ultimate conclusion of disability. The case solidifies the principle that an opinion of 'disabled' is not dispositive; it must be consistently supported by objective medical evidence. This precedent makes it more difficult for claimants to succeed when their treating physicians' conclusory statements are undermined by the underlying medical data.
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