Waiver of Non‑Attorney Representation and Limits on the ALJ’s Duty to Develop the Record in Social Security Hearings

Commentary on: Phyllis J. Geyer v. Commissioner of Social Security, No. 24‑11246 (11th Cir. Dec. 5, 2025) (unpublished, per curiam)

I. Introduction

This Eleventh Circuit decision, though designated “Not for Publication,” offers a compact but important reaffirmation of several recurring principles in Social Security disability litigation:

What constitutes a valid waiver of the right to representation, including by a non‑attorney representative such as a family member;
The scope of the Administrative Law Judge’s duty to develop the record when a claimant appears without counsel or other representative;
How appellate courts apply the “substantial evidence” standard when reviewing an ALJ’s findings on:
- Residual Functional Capacity (RFC) – especially light vs. sedentary work;
- The timing of functional loss (here, bilateral fine manipulation) in a progressive or stepwise medical history; and
- The evaluation of medical opinion evidence under the SSA’s post‑2017 regulations.

The case arises from claimant Phyllis J. Geyer’s effort to obtain disability insurance benefits (DIB) not just after a second, more disabling stroke in 2022, but also for the period following an earlier stroke in 2018. The ALJ found her disabled as of her second stroke (February 8, 2022) but not before. Geyer appealed, arguing primarily that her hearing was unfair because her daughter was not permitted to represent her or testify, and that the ALJ’s RFC findings for the pre‑2022 period lacked substantial evidentiary support.

The Eleventh Circuit affirmed, holding that:

Geyer validly waived her right to representation, including representation by her daughter;
The ALJ did not breach his obligation to develop the record by declining to call Geyer’s daughter as a witness;
The ALJ’s findings concerning:
- Her ability to perform a reduced range of light work prior to February 2022,
- The onset of inability to perform bimanual fine manipulation,
- The inapplicability of the Medical‑Vocational Guidelines (“the Grids”), and
- The weight assigned to Dr. Augusto de Leon’s medical opinion
were all supported by substantial evidence.

II. Factual and Procedural Background

A. The claimant and her medical history

Geyer’s vocational background is in sedentary, desk‑based jobs—loan consultant, merchandiser, insurance sales representative, member‑services representative, and telephone-based customer service work.

Her key medical events were:

September 2018: First stroke; symptoms included leg heaviness and dexterity issues. She was evaluated, diagnosed with a stroke, and discharged the next day. Her functioning fluctuated in the weeks that followed but was reported as “fine” at follow‑ups.
May 2019: Application for DIB, alleging disability beginning April 2019.
2019 consultative exam – Dr. Augusto R. de Leon:
- Complaints: right leg weakness, weak right hand grip, use of a crutch.
- Self‑reported abilities: could sit without limitation; could stand/walk for short periods; could perform daily activities (cooking, cleaning, finances).
- Findings: weaker right‑side strength but normal range of motion, dexterity, reflexes; she could get on/off the exam table with ease; could squat halfway and rise unassisted; walked unsteadily and used crutch as an assistive device.
State‑agency review – Dr. Shakra Junejo (October 2019):
- File review including de Leon’s exam.
- Assessment: capable of a reduced range of sedentary work.
2019–2021: Additional appointments documenting largely normal results and improvement in mobility.
February 2022: Second stroke; MRI showed extensive white matter changes consistent with a new cerebrovascular event.
May 2022: Hospital visit after a fall that fractured her hand; she attributed the fall to reduced mobility following the second stroke.
June 2022: Emergency room visit for hypertension.

B. Administrative proceedings

After the initial denial of her DIB claim, Geyer requested a hearing before an ALJ. Her prior attorney withdrew, stating he could not assist further after reviewing the file. While waiting for the hearing, her medical status was recorded as relatively stable until the second stroke in February 2022.

The June 2022 ALJ hearing included:

An express colloquy about representation, in which Geyer:
- Confirmed she wished to proceed without a lawyer;
- Mentioned she had spoken with SSA about having her daughter “not so much representing but as a witness”;
- Confirmed she did not want to postpone to obtain representation or to review her file.
Testimony from a vocational expert (VE) who classified her past telephone sales and customer-service positions as sedentary work (primarily sitting and talking).

The ALJ ultimately found:

Geyer had not engaged in substantial gainful activity since April 2019;
She had a severe impairment (post‑stroke residuals);
Her impairment did not meet or equal a listed impairment;
She retained the RFC to perform a reduced range of light work before February 8, 2022, including work consistent with her past sedentary jobs;
She became disabled as of February 8, 2022 (after the second stroke), when her functioning deteriorated to the point of precluding her past work.

Geyer appealed to the district court, and then to the Eleventh Circuit, challenging both procedural fairness (representation and witnesses) and the substantive RFC determinations.

III. Summary of the Eleventh Circuit’s Opinion

The Eleventh Circuit’s ruling can be distilled into six principal holdings, mirroring Geyer’s issues on appeal:

Waiver of representation – including non‑attorney representation: Geyer knowingly and voluntarily waived her right to any representative, lawyer or non‑lawyer, by:
- Explicitly stating she wished to proceed without a lawyer or other representative; and
- Declining a continuance to obtain representation (despite having previously been represented).
No duty to call daughter as a witness: Because Geyer validly waived representation, the ALJ’s duty to develop the record was only the “basic” duty, not the “special duty” applicable to unrepresented claimants who do not validly waive representation. Under that basic duty:
- The ALJ was not required to call every witness the claimant might prefer; and
- Geyer failed to show prejudice or evidentiary gaps caused by the absence of her daughter’s testimony, which the court deemed cumulative.
Light work finding supported by substantial evidence: The ALJ’s conclusion that Geyer could perform a reduced range of light work prior to February 2022 was supported by:
- Medical evidence showing improved standing and walking ability in 2019–2021;
- Her self‑reported daily activities; and
- The later medical history indicating a clear worsening only with the second stroke.
Medical‑Vocational Guidelines inapplicable: The Grids are relevant only at Step Five, when the question becomes whether a claimant who cannot perform past relevant work can adjust to other work. Because the ALJ found at Step Four that Geyer could perform her past relevant sedentary work up to 2022, the ALJ never reached Step Five and correctly did not consult the Grids.
Fine manipulation limitation begins only after second stroke: Substantial evidence supported the ALJ’s conclusion that the onset of significant bilateral fine manipulation limitations coincided with the second stroke (with documented drooling, voice changes, marked right‑sided heaviness, difficulty typing, hand/arm abnormalities, and a fracture after a fall), rather than dating back to 2018.
Evaluation of Dr. de Leon’s opinion proper under § 404.1520c: The ALJ:
- Reasonably found that some of Dr. de Leon’s more restrictive opinions were not well supported by his own clinical observations (supportability); and
- Reasonably weighed his opinion against later medical evidence indicating improvement (consistency), giving it only “limited value.”

On that basis, the panel affirmed the district court and, in turn, the Commissioner’s decision.

IV. Detailed Analysis

A. Waiver of the Right to Representation, Including Non‑Attorney Representatives

1. The underlying right and standard for waiver

Social Security claimants have a statutory right to representation, typically understood under 42 U.S.C. § 406 and related regulations, and recognized in Brown v. Shalala, 44 F.3d 931, 934 (11th Cir. 1995). That representation can be by:

an attorney, or
a qualified non‑attorney representative (including family members), so long as SSA’s appointment procedures are followed.

However, this right is waivable if the claimant is “fully informed” of it. Smith v. Schweiker, 677 F.2d 826, 828 (11th Cir. 1982). Where a claimant proceeds without representation:

If there is no valid waiver, the ALJ owes a “special duty” to develop the record.
If there is a valid waiver, the ALJ’s duty is limited to a “basic obligation” to ensure a full and fair record.

Even where the claimant appears pro se, remand is not automatic. Under Ware v. Schweiker, 651 F.2d 408, 413 (5th Cir. Unit A 1981), the claimant must demonstrate unfairness or clear prejudice caused by the lack of representation.

2. Application to Geyer: Why the court found a valid waiver

The ALJ opened the hearing by explicitly asking Geyer:

“Since you're here today without a lawyer or other representative am I correct in understanding you wish to proceed without such representation?”

Geyer answered: “I wish to proceed without a lawyer.” When she mentioned her daughter, she carefully framed it:

“not so much representing but as a witness to my condition.”

She then clarified:

“Other than that, I don't have an attorney or anyone else.”

Crucially, when the ALJ followed up with:

“Did you need more time to obtain representation?”

she responded “No,” and also declined to postpone the hearing to review her file.

The Eleventh Circuit underscores two factors supporting waiver:

Geyer had previously retained counsel, so she knew representation was available and had experienced it.
She expressly declined additional time to obtain representation, indicating an informed and voluntary choice.

In this context, the panel found it “patently clear” that Geyer waived her right not only to a lawyer but also to any “other representative,” which would include her daughter as a non‑attorney representative.

This reinforces that in the Eleventh Circuit, an explicit verbal waiver in a clear colloquy, combined with a refusal of a continuance to obtain representation, will generally be treated as a valid waiver, even if the claimant later expresses regret and wishes a family member had been allowed to represent her.

B. ALJ’s Duty to Develop the Record and the Decision Not to Call the Daughter as a Witness

1. The “basic” duty vs. the “special” duty

The duty to develop the record was articulated in Cowart v. Schweiker, 662 F.2d 731, 735 (11th Cir. 1981), and further explained in Graham v. Apfel, 129 F.3d 1420, 1422–23 (11th Cir. 1997):

Basic duty (when there is a valid waiver of representation): the ALJ must ensure a full and fair record but does not have to “scrupulously and conscientiously” probe for every possible favorable fact.
Special duty (when the claimant is unrepresented and did not validly waive representation): the ALJ must:
“scrupulously and conscientiously probe into, inquire of, and explore for all the relevant facts and … be especially diligent in ensuring that favorable as well as unfavorable facts and circumstances are elicited.”

Because the court held Geyer did waive representation, the ALJ was under only the basic duty.

2. No per se duty to call every requested witness

Geyer argued that even with a valid waiver, the ALJ had a duty to call her daughter as a witness to fully develop the record. The Eleventh Circuit rejected this view:

The ALJ is not required “to hear any witness that [the claimant] wanted to call.”
The standard is whether “the record as a whole is incomplete or inadequate.” Graham, 129 F.3d at 1423.

To obtain remand for failure to develop the record, Clark v. Schweiker, 652 F.2d 399, 404 (5th Cir. Unit B 1981) requires a:

“showing of such a clear prejudice or unfairness … caused by … lack of counsel as would warrant a reconsideration of [the] claims.”

Geyer did not:

Identify new, material information her daughter would have supplied that was not already in Geyer’s own testimony or in the medical records; nor
Show that the omission of the daughter’s testimony created an evidentiary gap that undermined the fairness or correctness of the decision.

The court therefore agreed with the district court that Geyer had “established no prejudice” arising from the ALJ’s failure to call the daughter, and it affirmed on this point.

C. Substantial Evidence Review of RFC and Timing of Disability Onset

1. The five‑step sequential evaluation framework

The court briefly recapped the regulatory five‑step process (20 C.F.R. § 404.1520(a)(4)):

Step 1: Substantial gainful activity?
Step 2: Severe impairment lasting at least 12 months?
Step 3: Does the impairment meet or equal a listed impairment?
Step 4: Can the claimant perform past relevant work in light of RFC?
Step 5: If not, can the claimant adjust to other work, considering RFC, age, education, and experience?

The decisive step here is Step 4. The ALJ found Geyer’s RFC allowed performance of her past sedentary work before February 8, 2022, and thus she was not disabled during that period; only after the second stroke did she become unable to perform that work.

2. Light work vs. sedentary work before 2022

A critical dispute was whether Geyer was limited to sedentary work (as Dr. Junejo had opined in 2019) or could handle a reduced range of light work during the pre‑2022 period.

By regulation, light work (20 C.F.R. § 404.1567(b)) generally involves:

Lifting up to 20 pounds occasionally and up to 10 pounds frequently; and
Either “a good deal of walking or standing” or, if mostly sitting, “some pushing and pulling of arm or leg controls.”

Sedentary work, in contrast, predominantly involves sitting, with only occasional walking and standing, and lower exertional requirements.

Geyer argued that Dr. Junejo’s 2019 sedentary RFC must control the ALJ’s RFC. The ALJ, and the Eleventh Circuit, rejected this, emphasizing:

Longitudinal evidence: Subsequent 2019–2021 medical records showed improvement in Geyer’s standing and walking capacity.
Daily activities: Geyer reported the ability to perform household tasks, manage finances, cook, and clean, consistent with better functional capacity than the early sedentary assessment might suggest.
No re‑injury or worsening until 2022: The marked decline appears only with the second stroke, supported by new imaging and symptoms.

Under the governing standard from Richardson v. Perales, 402 U.S. 389, 401 (1971), “substantial evidence” means “more than a mere scintilla” and “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” The Eleventh Circuit held that the ALJ’s light‑work RFC comfortably met that standard.

3. The Medical‑Vocational Guidelines (“Grids”) and the Step‑Four Denial

Geyer suggested that the ALJ may have characterized her RFC as light, rather than sedentary, simply to avoid the application of the Grids, under which a claimant of her age and background performing only sedentary work might well be found disabled.

The court, citing Walker v. Bowen, 826 F.2d 996, 1002 (11th Cir. 1987), emphasized that:

The Grids become relevant only at Step Five, “to determine whether the applicant is able to pivot to new work.”
Because the ALJ found at Step Four that Geyer could still perform her past relevant work up to 2022, there was no obligation to consult or apply the Grids.

Thus, the allegation that the ALJ mis‑characterized her RFC to “bypass” the Grids fails at two levels:

The light‑work RFC is supported by substantial evidence; and
As a matter of law, Step Five and the Grids are not reached when a valid Step‑Four denial is made.

4. Onset of bilateral fine manipulation limitations

Geyer also argued that her ability to perform bimanual fine manipulation (e.g., typing, using her hands for detailed work) had been compromised since 2018. The ALJ—and the Eleventh Circuit—found otherwise.

The court highlighted evidence that:

Prior to 2022, Geyer’s exams reflected largely normal dexterity, with some right‑sided weakness but no marked fine‑motor deficits documented in clinical detail.
After the second stroke in 2022, however, she had:
- Drooling and voice changes;

The Eleventh Circuit deferred to the ALJ’s interpretation that:

This constellation of new, more severe findings marked the onset of significant fine‑manipulation limitations; and
Earlier complaints and mild weakness did not amount to the disabling level claimed by Geyer.

Given that reasonable minds could differ but the record reasonably supported the ALJ’s chronology, the court held that its role under the substantial‑evidence standard is not to re‑weigh the evidence.

D. Evaluation of Medical Opinion Evidence Under 20 C.F.R. § 404.1520c

1. Post‑2017 framework: supportability and consistency

For claims filed on or after March 27, 2017, the SSA abandoned the “treating physician rule” and adopted a factor‑based approach in 20 C.F.R. § 404.1520c. The ALJ must consider:

Supportability: How well the medical opinion is supported by objective medical evidence and explanations.
Consistency: How consistent the opinion is with the evidence from other medical and non‑medical sources.
Relationship to the claimant (length, frequency, purpose, extent, examining vs. non‑examining).
Specialization of the medical source.
Other relevant factors.

Regulations make the first two factors—supportability and consistency—“the most important factors”, and require ALJs to expressly explain how these were considered. § 404.1520c(b)(2).

2. The ALJ’s treatment of Dr. de Leon’s opinion

The ALJ assigned “limited value” to some of Dr. de Leon’s more restrictive findings. The Eleventh Circuit endorsed this based on:

Supportability:
- Dr. de Leon noted that Geyer used a crutch and had right‑side weakness, but he also observed her:
  - Get on and off the exam table with ease;
  - Squat halfway and rise unassisted;
  - Perform exam‑related maneuvers without relying on the cane.
- Geyer reported the ability to perform daily activities like cooking, cleaning, and managing finances.
- The ALJ reasonably concluded that opinions suggesting more extreme work‑related limitations lacked strong support in the objective findings and self‑reports contained within the same exam.
Consistency:
- The ALJ pointed out that Dr. de Leon’s exam occurred relatively soon after the first stroke, whereas later records showed improvement in Geyer’s mobility and functioning.
- These later records made Dr. de Leon’s more restrictive views less consistent with the overall longitudinal picture, reducing their weight.

The Eleventh Circuit did not require the ALJ to adopt or even heavily credit this consultative opinion merely because it came from an examining physician. Instead, consistent with § 404.1520c, the court accepted that:

An ALJ may discount a medical opinion when it is only weakly supported by its own findings and is inconsistent with subsequent, more persuasive evidence.
What matters is that the ALJ articulate a rational, evidence‑based explanation tied to supportability and consistency, which the ALJ did here.

The Geyer decision thus reflects and reinforces the post‑2017 regulatory regime: there is no controlling weight for any medical source, and the logical bridge between evidence and RFC is the key focus in appellate review.

V. Precedents Cited and Their Influence on the Decision

1. Richardson v. Perales, 402 U.S. 389 (1971)

Perales is the foundational Supreme Court case on the meaning of “substantial evidence” in Social Security cases. The Eleventh Circuit quotes its definition:

“more than a mere scintilla” and “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”

Perales undergirds the highly deferential review of ALJ fact‑finding. In Geyer, it legitimizes the court’s choice not to re‑weigh competing evidence regarding functional capacity and onset dates.

2. Graham v. Apfel, 129 F.3d 1420 (11th Cir. 1997)

Graham is cited for:

The duty to develop the record;
The standard for showing prejudice (requiring that the record be incomplete or inadequate).

The Geyer panel uses Graham to:

Describe the “special duty” owed to unrepresented claimants without valid waivers; and
Explain why, in Geyer’s case, the absence of her daughter’s testimony did not create a prejudicial evidentiary gap.

3. Walker v. Social Security Administration, 987 F.3d 1333 (11th Cir. 2021)

Walker is cited for the standard of review at the appellate level: the Eleventh Circuit reviews:

Legal conclusions de novo;
The district court’s determination that the Commissioner’s factual findings are supported by substantial evidence, also de novo.

Walker frames the appellate role: whether the district court correctly concluded the agency’s decision satisfied the substantial‑evidence standard.

4. Brown v. Shalala, 44 F.3d 931 (11th Cir. 1995)

Brown establishes:

The claimant’s statutory right to counsel in SSA proceedings; and
The ALJ’s heightened “special duty” to develop the record for unrepresented claimants lacking a valid waiver.

Geyer narrows Brown’s reach by holding that once a claimant validly waives representation, that special duty does not apply, and only the basic duty to develop the record remains.

5. Smith v. Schweiker, 677 F.2d 826 (11th Cir. 1982)

Smith deals with what is needed for a knowing and intelligent waiver of the right to representation. Geyer uses Smith to support the notion that waiver is valid when the claimant:

Is fully informed of the right to counsel; and
Explicitly chooses to proceed without representation.

Geyer adds that prior experience with counsel can help show the claimant understood the right she was waiving.

6. Ware v. Schweiker, 651 F.2d 408 (5th Cir. Unit A 1981)

Ware articulates the rule that even in the absence of representation, a claimant must show unfairness or clear prejudice to obtain remand. The Geyer panel invokes this to emphasize that:

Even if some imperfection in procedure existed, it would not warrant remand without a showing of prejudice.
Because Geyer did not demonstrate that the absence of her daughter’s testimony affected the outcome, remand was unwarranted.

7. Cowart v. Schweiker, 662 F.2d 731 (11th Cir. 1981)

Cowart is the leading Eleventh Circuit case on the ALJ’s duty to develop the record, distinguishing between the basic duty and the special duty. Geyer cites Cowart to:

Define the ALJ’s “basic obligation to develop a full and fair record” after a valid waiver; and
Clarify that the “special duty” is triggered only when there is no valid waiver.

8. Clark v. Schweiker, 652 F.2d 399 (5th Cir. Unit B 1981)

Clark is used for the proposition that remand requires a showing of “clear prejudice or unfairness” caused by the lack of counsel. The Geyer court applies Clark to conclude that Geyer failed this test: her arguments about her daughter’s testimony were too speculative and conclusory.

9. Walker v. Bowen, 826 F.2d 996 (11th Cir. 1987)

Walker clarifies that the Medical‑Vocational Guidelines come into play only at Step Five, after a finding that the claimant cannot do past relevant work. Geyer relies on Walker to:

Justify the ALJ’s decision not to use the Grids, since the case was resolved at Step Four; and
Reject the argument that mislabeling RFC to avoid the Grids is itself error, absent a faulty Step‑Four finding.

VI. Impact and Practical Implications

A. For claimants and representatives

Waiver is taken seriously: A claimant’s statement on the record that she wishes to proceed without a representative, especially after being advised of the right and offered a continuance, will almost certainly be treated as a valid waiver in the Eleventh Circuit.
Non‑attorney representation must be clearly invoked: If a claimant wants a family member to act as a representative (not merely as a witness), that must be made explicit, and SSA’s representative appointment process should be completed in advance.
Prejudice is required: Complaints about not calling a family member or additional witness will not support remand without a showing of what new, material evidence their testimony would provide and how that would likely change the outcome.

B. For ALJs

Colloquy matters: An ALJ who:
- Advises a claimant of the right to representation (including non‑attorney representatives);
- Expressly asks if the claimant wishes to proceed without representation; and
- Offers a continuance to obtain representation or review the file;
will be well‑positioned to defend a finding of valid waiver on appeal.
No obligation to call cumulative witnesses: Under the basic duty to develop the record, ALJs are not required to call every witness a claimant suggests, especially when testimony would be duplicative of medical records and claimant testimony.
RFC must be dynamic and longitudinal: ALJs may (and must) consider how a claimant’s medical condition changes over time, including improvements, rather than freezing functional capacity at an early consultative exam.

C. For district courts and appellate courts

Reaffirmation of deferential review: Geyer reinforces that when there is any reasonable evidentiary basis for an ALJ’s RFC findings and timing of disability onset, appellate courts will not re‑weigh the evidence.
Structured analysis of medical opinions: The case underscores the importance of checking for explicit ALJ discussion of supportability and consistency under § 404.1520c, rather than mechanically enforcing “treating physician” deference.

D. Limitations: Unpublished, but instructive

Because this decision is unpublished (“Not for Publication”), under Eleventh Circuit rules it is not binding precedent, but it can be cited for its persuasive value. It nonetheless:

Illustrates how the Eleventh Circuit currently views waiver, ALJ duties, and substantial evidence review; and
Provides practical guidance for practitioners in framing (and challenging) SSA decisions in this circuit.

VII. Complex Concepts Simplified

1. Residual Functional Capacity (RFC)

RFC is what a claimant can still do in a work setting despite physical or mental limitations. It is:

Expressed in terms of exertional level (sedentary, light, medium, heavy) and non‑exertional limitations (postural, manipulative, environmental, mental);
Used to answer whether the claimant can perform past work (Step Four) or any other work (Step Five).

2. Light work vs. sedentary work

Sedentary work:
- Mainly sitting;
- Occasional walking and standing;
- Lower lifting requirements (typically up to 10 pounds).
Light work:
- More walking and standing, or use of arm/leg controls even if mostly sitting;
- Lifting up to 20 pounds occasionally and 10 pounds frequently.

In many cases, particularly for older claimants, being limited to sedentary work can lead to a finding of disability under the Grids, whereas the ability to do light work often results in a denial.

3. The Medical‑Vocational Guidelines (“the Grids”)

The Grids are tables the SSA uses at Step Five to determine whether jobs exist in the national economy for a person with a particular combination of:

RFC (sedentary, light, etc.);
Age;
Education; and
Work experience/transferable skills.

They do not apply at Step Four. If the claimant can still do past relevant work, the Grids are never reached.

4. Substantial evidence

“Substantial evidence” is a low but real threshold: more than a mere trace of evidence, but less than the weight of the evidence. The key questions for a court are:

Is there some reasonable evidentiary basis for the ALJ’s conclusion?
Did the ALJ apply the correct legal standards?

If both are true, the court must affirm, even if it might have decided differently on a de novo review of the facts.

5. Waiver of the right to representation

A claimant has the right to a lawyer or other representative but can waive that right if:

She is told about the right; and
She clearly chooses to proceed alone, especially after being offered time to obtain representation.

Once a valid waiver occurs, the ALJ’s obligations are less demanding than when a claimant is unrepresented without a valid waiver.

6. “Special duty” vs. “basic duty” to develop the record

Basic duty: Always applies; ALJ must ensure the record is complete enough to decide the case fairly.
Special duty: Applies when the claimant is unrepresented and did not validly waive representation; the ALJ must more aggressively explore all potentially favorable facts and ask probing questions.

Geyer confirms that once the court finds a valid waiver, only the basic duty applies.

7. Supportability and consistency of medical opinions

Under 20 C.F.R. § 404.1520c:

Supportability: Does the doctor back up the opinion with examination findings, test results, and a clear explanation?
Consistency: Does the opinion line up with other medical records and evidence in the file?

Opinions that are weakly supported or inconsistent with the broader record may properly be given little weight, even if they come from examining or treating sources.

VIII. Conclusion

Geyer v. Commissioner of Social Security does not break new doctrinal ground, but it consolidates and illustrates several important principles in Eleventh Circuit Social Security law:

A clear on‑the‑record statement that a claimant wishes to proceed without a lawyer or other representative, coupled with a refusal of a continuance to obtain representation, will be treated as a valid waiver of representation, including non‑attorney representation by a family member.
Once representation is validly waived, the ALJ’s duty to develop the record is limited to the basic duty, not the “special duty” applicable to unrepresented claimants lacking such a waiver.
Alleged procedural errors—like not calling a family member as witness—will not justify remand absent a concrete showing of prejudice and evidentiary gaps.
The substantial evidence standard remains highly deferential: the Eleventh Circuit will uphold ALJ determinations on RFC and onset dates if there is any reasonable evidentiary basis, even if earlier medical opinions suggested more severe limitations.
The case exemplifies practical application of the post‑2017 rules governing medical opinion evaluation, emphasizing supportability and consistency over formal status as treating or examining physician.
Finally, the decision reinforces the stepwise structure of disability evaluation: where the ALJ validly finds at Step Four that a claimant can perform past relevant work, the Medical‑Vocational Guidelines at Step Five are simply not in play.

For practitioners, Geyer is a cautionary tale on the importance of:

Ensuring claimants understand the implications of proceeding without representation;
Building a clear record of non‑duplicative lay testimony when seeking remand on record‑development grounds; and
Framing appeals in terms that directly confront the substantial evidence threshold and the longitudinal nature of RFC assessment.

Although unpublished and therefore not binding precedent, Geyer will likely be cited within the Eleventh Circuit as a persuasive example of how courts scrutinize waiver, ALJ obligations, and evidentiary sufficiency in Social Security disability appeals.