Eleventh Circuit: Treating physician's opinion properly discounted where physician was one-time examiner
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Thursday, June 13, 2019

Eleventh Circuit: Treating physician's opinion properly discounted where physician was one-time examiner

By Payroll and Entitlements Editorial Staff

A treating physician’s opinion must be given substantial weight absent good cause shown to the contrary. Here, the claimant argued that the ALJ failed to give adequate weight to the opinions of his treating and examining physicians and gave too much weight to the opinions of consulting physicians. The ALJ determined that the claimant suffered from four severe impairments, but that he had the residual functional capacity to perform sedentary work with certain limitations. Although the claimant’s examining physician opined that the claimant was markedly impaired in several categories of mental functioning, the court concluded that substantial evidence supported the ALJ’s decision to give little weight to the opinion. The physician was a one-time examiner, his opinions were not supported by clinical or objective evidence in the record, and were contradicted by other medical opinions. Likewise, substantial evidence supported giving little weight to the opinion of the claimant’s treating psychiatrist. The psychiatrist’s records contained no evidence to support the opinions about the claimant’s memory or reduced intellectual functioning and were inconsistent with that of another acceptable medical source. Moreover, the treatment records indicated that the claimant’s condition was well controlled by medication. The court also found the ALJ committed no error in giving the opinions of certain consulting professionals more weight. The state medical consultants’ opinions included sufficient supporting explanation. The denial of benefits was affirmed (Manuel A. Cruz Machuat v. Commr., CA-11 (Unpub. Op.), No. 18-12638, May 2, 2019 ).

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