Eason v. Social Security Administration, Commissioner

Teresa Eason applied for Social Security disability benefits, alleging impairments including back disorders, depression, and anxiety. An administrative law judge (ALJ) denied the claim, finding that her statements concerning the intensity, persistence, and limiting effects of her symptoms were not fully credible and that she retained the residual functional capacity to perform her past relevant work. The district court affirmed the Commissioner's decision. On appeal to the United States Court of Appeals for the Eleventh Circuit, argued and decided on April 23, 2018, the court evaluated whether the ALJ properly applied the Eleventh Circuit pain standard and whether the decision was supported by substantial evidence.

The United States Court of Appeals for the Eleventh Circuit affirmed the Commissioner's final decision, holding that the ALJ articulated specific reasons for discrediting Eason's testimony and that the decision was supported by substantial evidence.

Whether the administrative law judge properly evaluated Teresa Eason's subjective complaints of pain under the Eleventh Circuit's three-part pain standard, and whether the residual functional capacity finding was supported by substantial evidence in the record.

The case reinforced the broad discretion given to ALJs in evaluating subjective pain testimony within the Eleventh Circuit, underscoring that a claimant's failure to meet the strict requirements of the pain standard, combined with inconsistencies in the medical record, justifies the denial of benefits.