Shoemaker v. Social Security Administration, Commissioner

Clinton Shoemaker applied for disability insurance benefits, claiming that fibromyalgia and other impairments prevented him from working. After an Administrative Law Judge denied his claim, Shoemaker appealed to the federal district court, which affirmed the denial. He then appealed to the United States Court of Appeals for the Eleventh Circuit. In an unpublished per curiam decision issued on March 17, 2023, the appellate court reviewed whether the ALJ had properly evaluated the medical opinion evidence and Shoemaker's subjective complaints. The court held that the ALJ's findings were supported by substantial evidence and that the ALJ had articulated adequate reasons for discounting certain medical opinions and testimony. The denial of benefits was therefore affirmed.

The United States Court of Appeals for the Eleventh Circuit affirmed the district court's judgment, concluding that the ALJ's decision to deny disability benefits was supported by substantial evidence.

Whether the Administrative Law Judge properly evaluated the medical opinion evidence and the claimant's subjective complaints regarding fibromyalgia symptoms in accordance with applicable regulations and the substantial evidence standard.

The decision reinforces the deference federal courts give to ALJs under the substantial evidence standard, particularly in cases involving fibromyalgia and other conditions where disability determinations depend heavily on subjective symptom evaluation.