Supportability and Consistency Reaffirmed: Eleventh Circuit’s Guidance on ALJ Evaluation of Medical Opinions in Social Security Disability Appeals

Introduction

Joseph Davis v. Commissioner of Social Security, decided April 16, 2025 by the United States Court of Appeals for the Eleventh Circuit, addresses the proper method by which an Administrative Law Judge (ALJ) must evaluate medical opinions and the claimant’s own testimony under the post-2017 regulations. In this appeal, Davis seeks review of the district court’s order affirming the ALJ’s denial of his application for disability insurance benefits (DIB). Before the ALJ, Davis claimed disability based on low vision, chronic back pain, difficulty standing, sitting, and walking long periods—conditions that allegedly rendered him unable to sustain full-time work since February 23, 2019. After extensive medical records, expert opinions, and a hearing, the ALJ concluded that Davis retained the residual functional capacity (RFC) for light work, and the Eleventh Circuit affirmed.

Summary of the Judgment

The Eleventh Circuit affirmed the Commissioner’s denial of benefits, holding that the ALJ (1) properly applied the two “most important” factors—supportability and consistency—in evaluating medical opinions under 20 C.F.R. § 404.1520c, (2) reasonably discounted the most restrictive opinion of Davis’s treating physician based on objective medical evidence and conflicting prior reports, and (3) correctly applied the two-part “pain standard” when assessing Davis’s subjective symptoms, finding substantial evidence supported the ALJ’s RFC determination. The court rejected arguments that the ALJ erred by grouping medical opinions in a single paragraph or failing to articulate the weight given to each opinion.

Analysis

1. Precedents Cited

Samuels v. Acting Commissioner of Social Security, 959 F.3d 1042 (11th Cir. 2020). Establishes that when the Appeals Council denies review, the ALJ’s decision becomes the final decision for appellate review.
Winschel v. Commissioner of Social Security, 631 F.3d 1176 (11th Cir. 2011). Clarifies that the ALJ must articulate the weight assigned to medical opinions and that substantial evidence means “more than a scintilla” of relevant evidence.
Raper v. Commissioner of Social Security, 89 F.4th 1261 (11th Cir. 2024). Stresses that an ALJ must consider statements from medical sources and lay witnesses in determining RFC, and that supportability and consistency are the two “most important” factors in evaluating medical opinions under the revised regulations.
Moore v. Barnhart, 405 F.3d 1208 (11th Cir. 2005). Describes the claimant’s burden to prove disability under the five-step sequence.
Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002). Articulates the two-part pain standard: establishing an underlying condition and showing the condition could reasonably produce the alleged pain.
Holt v. Sullivan, 921 F.2d 1221 (11th Cir. 1991). Extends the pain standard to other subjective symptoms beyond pain.
Buckwalter v. Acting Commissioner of Social Security, 5 F.4th 1315 (11th Cir. 2021). Affirms that an ALJ must consider all relevant evidence in crafting an RFC.

2. Legal Reasoning

Under 20 C.F.R. § 404.1520c, the ALJ must evaluate every medical opinion using five factors—supportability, consistency, relationship with the claimant, specialization, and other factors—with supportability and consistency being paramount. The ALJ’s written decision need only explain how these two factors were considered. Here, the ALJ:

Supportability:
The ALJ noted that state‐agency evaluator Dr. Cordero’s opinion was supported by objective findings in Davis’s treatment records—namely, multiple examinations showing largely normal neurological function and reports of temporary improvement after conservative treatment.
Consistency:
The ALJ observed that Dr. Cordero’s assessment aligned with earlier workers’ compensation reports from Davis’s treating physician, Dr. Richman, who likewise imposed only modest lifting restrictions without limiting standing or sitting. The ALJ contrasted this with Dr. Richman’s later, more restrictive June 2021 opinion, finding that it conflicted with Dr. Richman’s own earlier assessments and with Davis’s admitted activities (walking daily with his dog, driving, shopping, and assisting at home).
Symptom Evaluation:
Applying the two-part pain standard from Wilson, the ALJ acknowledged Davis’s back injury and ongoing pain, but reasonably concluded that the alleged intensity and persistence of his symptoms were inconsistent with objective medical evidence (MRI, EMG, normal exam findings) and his daily activities. The ALJ also considered the conservative nature of Davis’s treatment (injections, medications, no surgery) and his ability to walk, stand, and sit for longer than claimed.

3. Impact

Although the decision does not break new doctrinal ground, it reinforces several important principles in Eleventh Circuit Social Security jurisprudence:

It confirms the sufficiency of a combined discussion of multiple medical opinions so long as the ALJ clearly applies and explains the two key regulatory factors (supportability and consistency).
It emphasizes that ALJs may discount a treating physician’s outlier opinion when that opinion contradicts earlier reports by the same physician and the claimant’s own testimony about daily activities.
It reiterates the Eleventh Circuit’s broad reading of “substantial evidence” and deference to ALJ credibility determinations when adequately explained.
It offers guidance on how conservative treatment histories and reported functional activities may undermine claims of total disability.

Future Social Security appeals in this circuit will likely cite Davis to support a streamlined approach to weighing medical opinions and assessing claimant testimony under 20 C.F.R. § 404.1520c and the established pain-standard framework.

Complex Concepts Simplified

Residual Functional Capacity (RFC): The most a claimant can do despite physical or mental limitations, measured in terms of work‐related activities (e.g., lifting, standing, sitting).
Supportability: The degree to which a medical opinion is backed by relevant objective evidence (tests, imaging, exam findings).
Consistency: How well a medical opinion aligns with other evidence in the record—both medical and non‐medical.
Substantial Evidence: Relevant evidence that a reasonable person would accept as adequate to support a conclusion—more than a mere scintilla.
Pain Standard: A two-part test requiring (1) objective evidence of a condition and (2) proof that the condition can reasonably cause the claimed level of pain or other symptoms.
Five-Step Sequential Evaluation: The process SSA uses to decide disability: (1) engagement in substantial gainful activity; (2) severe impairments; (3) listed impairments; (4) ability to perform past work; (5) ability to perform other work.

Conclusion

The Eleventh Circuit’s decision in Joseph Davis v. Commissioner of Social Security reaffirms the procedural requirements for ALJs under the 2017 regulatory framework. By upholding the ALJ’s careful application of supportability and consistency in weighing medical opinions, and her reasoned evaluation of Davis’s subjective symptoms, the court underscores the deference accorded to well-explained administrative findings. Practitioners should note that a single, integrated analysis of multiple opinions is permissible if the ALJ adequately addresses the two “most important” factors, and that inconsistency with a claimant’s daily activities and conservative treatment history can justify discounting extreme restrictions. This decision will serve as a practical guide for both advocates and adjudicators in future Social Security disability litigation.