Perigo v. Social Security Administration, Commissioner

Melissa Perigo applied for Social Security Disability Insurance and Supplemental Security Income benefits, asserting she was disabled due to physical and mental impairments. An administrative law judge (ALJ) denied her claim, concluding she retained the ability to perform light work. The Appeals Council declined review, and the federal district court affirmed the Commissioner's decision. Perigo appealed to the Eleventh Circuit, arguing the ALJ improperly discounted her subjective pain complaints and failed to adequately weigh her mental health limitations. On September 19, 2018, the Eleventh Circuit issued a per curiam decision. The court found the ALJ gave specific, supported reasons for discrediting Perigo's testimony, highlighting inconsistencies with medical evidence and her daily activities. The panel held that substantial evidence backed the ALJ's residual functional capacity assessment and credibility determination, affirming the denial of benefits.

The United States Court of Appeals for the Eleventh Circuit affirmed the Commissioner's decision, holding that the ALJ's findings were supported by substantial evidence and that the credibility determination was properly articulated.

Whether the administrative law judge properly evaluated the claimant's subjective complaints of pain and mental impairments, and whether the denial of Social Security disability benefits was supported by substantial evidence.

The ruling reinforced the principle that reviewing courts will defer to an ALJ's credibility assessment as long as it is based on substantial evidence and clearly articulated. It emphasized that inconsistencies between a claimant's subjective testimony and objective medical records, as well as reported daily activities, may justify discrediting pain allegations in Social Security disability cases.