Burford v. Social Security Administration, Commissioner

On September 11, 2018, the U.S. Court of Appeals for the Eleventh Circuit issued an unpublished ruling in Michael Burford's appeal of a denial of Social Security disability benefits. Burford had alleged disability due to back impairment, depression, and other conditions. An Administrative Law Judge held a hearing and concluded Burford could still perform his past relevant work or adjust to other jobs in the national economy, thereby denying the applications. The district court affirmed the Commissioner’s decision. On appeal, Burford contended the ALJ improperly assessed his subjective complaints of pain and failed to accord sufficient weight to his treating physician’s opinion. The appellate court reviewed the record under the substantial evidence standard, held that the ALJ articulated adequate reasons for the credibility and medical evidence findings, and determined the denial was supported by the record as a whole.

The Eleventh Circuit affirmed the district court’s order, upholding the Commissioner of Social Security’s final decision denying disability benefits.

Whether the Administrative Law Judge properly evaluated the claimant's subjective complaints of pain and the medical opinion evidence from his treating physician in accordance with the applicable Social Security regulations.

The decision reinforces the highly deferential substantial evidence standard applied in federal review of Social Security disability determinations. It underscores the difficulty claimants face in overturning an ALJ's credibility and medical evidence findings on appeal, contributing to precedent that emphasizes judicial restraint when reviewing agency factual assessments and further solidifying the administrative process's role as the primary factfinder.