Lasater v. Social Security Administration, Commissioner

Jane Lasater applied for Social Security Disability Insurance benefits, alleging disability due to degenerative disc disease and major depressive disorder. The Social Security Administration denied her claim initially and on reconsideration. Following a hearing, an Administrative Law Judge (ALJ) determined that Lasater retained the residual functional capacity to perform a limited range of light work and was therefore not disabled. The Appeals Council declined review, and a federal district court affirmed the ALJ’s decision. On further appeal to the Eleventh Circuit, Lasater contended that the ALJ improperly rejected the opinions of her long-time treating physician and failed to adequately evaluate her subjective complaints of pain and functional limitations. The case was argued in late 2025 and decided on January 26, 2026.

The United States Court of Appeals for the Eleventh Circuit reversed the district court’s judgment and remanded the case to the agency. The panel held that the ALJ failed to articulate good cause for discounting the treating source’s opinion and did not provide sufficient reasoning grounded in substantial evidence for rejecting the claimant’s pain testimony.

Whether the Administrative Law Judge properly evaluated the treating physician’s medical opinions and the claimant’s subjective symptom testimony under applicable regulations, and whether the residual functional capacity finding was supported by substantial evidence.

The decision reinforces strict compliance with evidentiary standards in Social Security disability adjudications. It signals to ALJs that conclusory dismissals of treating physician opinions and subjective symptom allegations will face heightened judicial scrutiny, potentially leading to more thorough administrative decisions and fewer arbitrary denials nationwide.