Zinta Harner v. Social Security Administration, Commissioner, No. 21-12148 (11th Cir. 2022)
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Plaintiff applied for disability benefits, alleging that, as of August 2016, she was unable to work because of degenerative disc disease, bulging and herniated discs, other spine issues, fatigue, migraines, asthma, fatty liver, and food allergies. The district court affirmed the decision of the administrative law judge denying Plaintiff's claims. The district court determined that section 404.1520c, and not the treating-physician rule, applied to Plaintiff’s claim. Plaintiff argued that the court's earlier precedents establishing and applying the treating-physician rule are still good law, notwithstanding the promulgation of section 404.1520c.
The Eleventh Circuit affirmed, finding that the new regulation validly abrogated the treating-physician rule and applied to Plaintiff’s claim. The court found that the new regulation instructs administrative law judges to give a treating physician’s opinion no deference and instead to weigh medical opinions based on their persuasiveness. The Social Security Act (“Act”) conferred “exceptionally broad authority” to the Commissioner “to prescribe standards for applying certain sections of the . . . Act.” The court explained that it has never held that the treating-physician rule is unambiguously required by the Act.
Here, Plaintiff filed her disability claim on April 28, 2017, after the effective date for section 404.1520c. And because section 404.1520 forbids administrative law judges from “defer[ring] or giv[ing] any specific evidentiary weight, including controlling weight, to any medical opinion(s),” 20 C.F.R. Section 404.1520c(a), the administrative law judge did not err by declining to give more weight to the medical opinions of Plaintiff’s treating physicians.
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