Hancock v. Barnhart
Docket: No. 06-1621-cv
Court: Court of Appeals for the Second Circuit; January 29, 2009; Federal Appellate Court
Edward Hancock appeals an order from the District Court that granted the Commissioner of Social Security's motion for judgment on the pleadings, upholding the denial of his disability insurance benefits claim under the Social Security Act. Hancock contends that the Administrative Law Judge (ALJ) improperly favored the testimony of Dr. Gerald Greenberg, a medical expert, over that of his treating physicians and disregarded a vocational expert's statement indicating he could not perform his previous work. The appeal is reviewed de novo, with the possibility of overturning the Commissioner’s decision only if it lacks substantial evidence or is based on incorrect legal standards. The court finds that the decision that Hancock can perform his previous work is backed by substantial evidence, notably from various doctors regarding his residual functional capacity. The ALJ was justified in prioritizing opinions from other physicians over the treating physicians' views, particularly when the latter lacked objective medical evidence to support their claims, as outlined in 20 C.F.R. 404.1527(d)(2). Furthermore, the treating physicians' assessments were inconsistent with other substantial evidence, including opinions from other medical experts. The court also ruled that the Commissioner did not err in dismissing the vocational expert's opinion. The expert did not state that Hancock could not perform his previous work but rather speculated about a hypothetical individual with specific residual function limitations. After evaluating all arguments presented by Hancock, the court found them unpersuasive and affirmed the District Court's judgment.