瓦尔农诉社会保障管理局专员案

Barry L. Varnon filed an application for disability insurance benefits with an alleged onset date of December 24, 2020. His application was denied at the initial and reconsideration levels. An Administrative Law Judge held a hearing on January 23, 2023, and denied his claims on March 9, 2023. The Appeals Council declined review on November 17, 2023, making the ALJ’s decision final. Varnon then filed a complaint in the U.S. District Court for the Northern District of Alabama on January 22, 2024. On December 17, 2024, the court reviewed the Commissioner’s decision to determine whether it was supported by substantial evidence and based upon proper legal standards.

The court affirmed the Commissioner’s decision, holding that the denial of disability benefits was supported by substantial evidence. The case was subsequently appealed to the Eleventh Circuit, which affirmed the denial on February 12, 2026.

Whether the ALJ’s denial of Varnon’s disability benefits was supported by substantial evidence and based on proper legal standards. Specifically, Varnon contended that the ALJ erred by failing to consider reports from recent employers, which Varnon characterized as “work attempts” or “work evaluations” under Social Security Ruling 98. The court rejected this characterization.

The case highlights the deferential “substantial evidence” standard in Social Security disability appeals. The Eleventh Circuit’s unpublished decision reinforces that courts may not reweigh evidence or substitute their judgment for that of the Commissioner, demonstrating the high bar claimants face in challenging adverse disability determinations.