No “Magic Words” Required: Eleventh Circuit Clarifies Weighting of Treating Physicians’ Opinions

Introduction

In Jill Capobianco v. Commissioner, Social Security Administration (11th Cir. Mar. 19, 2025), the Eleventh Circuit addressed how an Administrative Law Judge (ALJ) must articulate reasons for discounting a treating physician’s opinion in a Social Security disability determination. Plaintiff–Appellant Jill Capobianco applied for disability insurance benefits and Supplemental Security Income, alleging that chronic migraines and other physical and mental impairments left her unable to work. The Social Security Administration (SSA) denied her claims, the district court affirmed, and Capobianco appealed pro se. Her principal argument on appeal focused on the ALJ’s treatment of the medical opinion of her treating neurologist, Dr. Kathie Kowalczyk.

Key issues:

Did the ALJ articulate “good cause” for discounting Dr. Kowalczyk’s opinions?
Must an ALJ use magic words like “controlling weight” or “little weight,” or is it enough to explain the basis for discounting?
Is the ALJ’s decision supported by substantial evidence?

Summary of the Judgment

The Eleventh Circuit, per curiam, affirmed the denial of benefits. It held that:

An ALJ need not use “magic words” when assigning weight to a treating physician’s opinion so long as the decision clearly articulates the grounds for discounting it.
Substantial evidence supported the ALJ’s decision to give Dr. Kowalczyk’s migraine questionnaire “little weight,” given the short treatment period, internal inconsistencies in the questionnaire, lack of corresponding progress notes, and unrevealing MRI scans.
All other issues raised on appeal were forfeited for failure to exhaust them in the district court.

As a result, the Court affirmed the ALJ’s findings at steps 1–5 of the SSA’s sequential evaluation, including the residual functional capacity assessment that Capobianco could perform a limited range of light work.

Analysis

Precedents Cited

Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004): Established that a treating physician’s opinion must be given “substantial or considerable weight” unless “good cause” exists to discount it.
Simon v. Commissioner, 7 F.4th 1094 (11th Cir. 2021): Reaffirmed the treating physician rule for claims filed before March 27, 2017, and reiterated the “good cause” standard.
Raper v. Commissioner, 89 F.4th 1261 (11th Cir. 2024): Confirmed that an ALJ need not employ “magic words” in explaining how medical opinions are weighed so long as the rationale is clear.
Doughty v. Apfel, 245 F.3d 1274 (11th Cir. 2001) and Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005): Reinforced the scope of appellate review—legal questions de novo; factual findings for substantial evidence.

Legal Reasoning

1. Treating Physician Rule and “Good Cause”
Because Capobianco filed her claim before March 27, 2017, the ALJ was bound to give controlling weight to a treating physician’s opinion unless there was “good cause” for discounting it. Good cause exists when:

The opinion is not bolstered by the evidence.
The evidence supports a contrary conclusion.
The opinion is conclusory or inconsistent with the physician’s own records.

Phillips, 357 F.3d at 1241.

2. Articulation Requirement and “Magic Words”
The ALJ did not expressly state, “I give little weight to Dr. Kowalczyk’s questionnaire.” Instead, he reviewed the questionnaire’s timing (four months into treatment), noted internal inconsistencies (one-to-two headaches per week vs. two-or-more per week), observed the lack of concurrent progress notes, and cited unremarkable MRI findings. The Eleventh Circuit held that this “thorough discussion” sufficed to show “good cause” even without talismanic terminology.

3. Substantial Evidence Review
On appeal, the Court did not reweigh the facts or substitute its judgment. It found that a reasonable factfinder could conclude from the record that Dr. Kowalczyk’s opinion was entitled to little weight under Phillips’s good-cause factors. Uncontradicted medical evidence (MRI scans) and missing explanatory notes undercut the migraine questionnaire.

Impact

This decision reinforces two key points for disability adjudications in the Eleventh Circuit:

An ALJ must still provide “good cause” for discounting a treating physician’s opinion under pre-2017 rules, but need not use specific weight-assignment terms so long as the rationale is clear.
Applicants proceeding pro se on appeal face a high bar to preserve and argue issues not presented in district court—most of Capobianco’s contentions were forfeited.

Future ALJs will cite Capobianco for clear explanations of why a treating physician’s opinion is discounted, focusing on the evidentiary record rather than formulaic language. Appellants will be reminded that a full evidentiary record and proper district-court advocacy are essential to preserve issues.

Complex Concepts Simplified

Treating Physician’s Opinion: A medical judgment by a doctor who has seen the patient over time. It often carries special weight in Social Security cases.
Good Cause: The legitimate reasons an ALJ can give to discount that special weight (e.g., lack of supporting evidence, internal inconsistencies).
Substantial Evidence: The legal standard requiring “such relevant evidence as a reasonable person would accept as adequate to support a conclusion.”
Magic Words: There is no requirement for ALJs to use specific phrases like “controlling weight”—they must only explain the basis for their decision clearly.
Five-Step Framework: The SSA’s sequential evaluation of disability, from current work activity (step 1) to ability to adjust to other work (step 5).

Conclusion

Jill Capobianco v. Commissioner, SSA, clarifies that Eleventh Circuit ALJs need not recite “magic words” when assigning weight to a treating physician’s opinion, provided they articulate “good cause” with clarity and tie their reasoning to the record. The decision upholds the principle that substantial evidence review demands deference to the ALJ’s fact-finding when supported by the evidence. For practitioners, the case underscores the importance of:

Maintaining a thorough treatment record.
Ensuring consistency between opinions and contemporaneous progress notes.
Arguing weight-assignment issues clearly at the administrative and district-court levels to preserve appellate review.

This ruling will guide future disability claims in the Eleventh Circuit and informs both claimants and adjudicators about the flexibility—and boundaries—of the treating physician rule.