Caitlin E. O'Hare appealed the denial of her claim for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. The Administrative Law Judge (ALJ) had determined that O'Hare was not disabled as of December 9, 2012, finding she retained the residual functional capacity to perform sedentary work. O'Hare argued that the ALJ failed to accord substantial weight to the opinions of her treating physicians regarding her severe impairments, including POTS, Ehlers-Danlos syndrome, and chronic fatigue. She specifically contended that her doctors' statements indicated she could not work due to the need to elevate her legs for most of the day. The district court previously rejected these challenges, and the D.C. Circuit reviewed whether the ALJ's decision rested on proper legal standards and was supported by substantial evidence.
The court applied the substantial evidence standard, which requires more than a scintilla of evidence but less than a preponderance. Under applicable regulations, treating physicians' opinions generally warrant controlling weight unless there are 'good reasons' to the contrary. The court found the ALJ provided such reasons. The ALJ recognized O'Hare's severe impairments but noted the record showed her symptoms improved and were controlled with medication for much of the relevant period. Specifically, the ALJ cited Dr. Houry's note stating O'Hare was doing 'great' on her treatment, Dr. Solomon's November 2015 note describing symptoms as 'dramatically improved,' and Dr. Hashefi's notes indicating medication alleviated joint pain. Regarding the critical issue of leg elevation, the ALJ rejected O'Hare's reliance on a single April 2016 statement by Dr. Solomon. The ALJ contrasted this with Dr. Solomon's November 2015 treatment notes, which reported only headaches and insomnia as persisting symptoms and stated O'Hare was 'doing very well' from a cardiac point of view. The court held that the ALJ did not unlawfully require objective evidence to contradict subjective complaints but properly weighed the totality of the record, including qualifying statements from the same physicians.
The Commissioner's final decision denying benefits remains in effect. The ruling reinforces that ALJs may assign less weight to treating physicians' opinions when the record reflects documented symptom improvement or medication control, even if the physician's opinion is uncontradicted. It clarifies that ALJs are permitted to weigh countervailing statements from treating physicians against a claimant's subjective complaints without violating Social Security Ruling 16-3p. The case is remanded to the district court's judgment, and the mandate is withheld for seven days pending any petition for rehearing.
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