## Facts

- Robert M. Wilson applied for Disability Insurance Benefits under Title II, alleging disability beginning December 31, 1993, due to leg and back pain and related conditions.
- Wilson’s insured status expired March 31, 1995, requiring him to prove disability on or before that date.
- Wilson had multiple impairments during the relevant period, including insulin-dependent diabetes with lower-extremity neuropathy, lumbar spondylosis and facet arthritis, coronary artery disease, entrapment neuropathy after hernia surgeries, and sympathetic mediated pain syndrome.
- An administrative law judge (ALJ) found Wilson had severe impairments but retained residual functional capacity to perform jobs existing in significant numbers in the national economy and denied benefits.
- A treating physician who treated Wilson during the relevant period opined that Wilson had greater functional limitations than the ALJ adopted.
- The ALJ declined to give the treating physician’s opinion controlling weight and effectively rejected it without articulating specific reasons or identifying the weight assigned, while suggesting the opinion “might” be accurate.
- The district court affirmed, treating any failure to provide reasons as harmless error because the denial was otherwise supported by substantial evidence.

## Issues

1. Whether the ALJ violated the treating physician regulation by failing to give “good reasons” for discounting the treating physician’s opinion.
2. Whether such a violation may be excused as harmless error when the record may otherwise support the ALJ’s decision.

## Decision

- The Sixth Circuit vacated the district court’s judgment and remanded for further administrative proceedings.
- The court held the ALJ violated the agency’s treating physician regulation by failing to articulate “good reasons” for discounting the treating physician’s opinion and failing to specify the weight given.
- The court held the error was not harmless on this record and could not be excused merely because substantial evidence might support the outcome.

## Legal Principles

- A treating source medical opinion receives controlling weight if well-supported by medically acceptable clinical and laboratory diagnostic techniques and not inconsistent with other substantial evidence in the record.
- If an ALJ does not give controlling weight to a treating physician’s opinion, the decision must provide specific, record-supported reasons for the weight assigned, stated clearly enough to permit meaningful review.
- The “good reasons” requirement is a binding procedural protection for claimants; failure to comply is a reviewable legal error distinct from the substantial-evidence inquiry.
- Harmless error in this context is limited; remand is generally required unless the treating opinion is patently deficient or the ALJ’s rationale is otherwise clearly apparent from the decision.

## Conclusion

The Sixth Circuit required remand because the ALJ failed to comply with the mandatory “good reasons” requirement for discounting a treating physician’s opinion, and that procedural violation was not harmless despite potential evidentiary support for the denial.


Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004)