Case Law Update: Cruz v. Commissioner of Social Security — Florida Federal Court Affirms DIB Denial Over Overhead Reaching and Therapist Checkbox Opinion

What happened

On November 5, 2026, the United States District Court for the Middle District of Florida (Ocala Division) affirmed the Social Security Administration’s denial of disability insurance benefits (DIB) in Carmen Maria Cruz v. Commissioner of Social Security, Case No. 5:26-cv-00134-PRL (captioned No. 5:26-cv-134-PRL). The court held that substantial evidence supported the administrative law judge’s (ALJ’s) residual functional capacity (RFC)—finding that a ban on bilateral overhead reaching addressed the “need for manipulative limitations”—and that the ALJ properly found a treating counselor’s checkbox opinion unpersuasive. The 12-page Order (Doc. 12) affirmed the decision under sentence four of 42 U.S.C. § 405(g) and closed the file.

Background and the ALJ’s decision

According to the Order, Ms. Cruz applied for Title II benefits under 42 U.S.C. §§ 401–434 on July 30, 2021, alleging disability beginning September 2, 2020. The agency denied the claim initially on August 16, 2022, and on reconsideration on November 28, 2023. After a May 24, 2024 hearing, the ALJ found her not disabled on July 21, 2024, and the Appeals Council denied review on January 22, 2026, making the decision final under 20 C.F.R. § 404.900(a)(5). She filed her federal suit on February 19, 2026.

Ms. Cruz was 53 years old on the date of the ALJ’s decision, with some college education and past work as a legal assistant. At step two, the ALJ found severe impairments of “cervical spondylosis with myelopathy, osteoarthritis and secondary fibromyalgia, unspecified depressive disorder, with moderate anxious distress, and PTSD, unspecified.”

The ALJ found she had the RFC to perform light work with additional postural, hazard, mental, and reaching limits—including carrying out simple tasks without a production rate pace, interacting occasionally with supervisors, co-workers, and the public, tolerating occasional workplace changes, and performing “no overhead reaching bilaterally.” Relying on vocational expert testimony at step five, the ALJ found she could work as a mailroom clerk (non-postal), cleaner, or price marker.

Why the court affirmed

Ms. Cruz raised two issues on appeal: whether substantial evidence supported the RFC as to manipulative limitations, and whether the ALJ properly evaluated the opinion of her treating licensed mental health counselor, LMHC Peluffo. The court rejected both arguments:

• Overhead reaching is a manipulative limitation. Explaining why Ms. Cruz was “more limited than previously determined” by state agency consultants, the ALJ wrote that physical therapy notes showed she “exhibited deficits in cervical range of motion, shoulder strength, and grip strength that would warrant further limitations to her ability to climb ladders, ropes, or scaffolds and show the need for manipulative limitations” (Exhibit 36F). Ms. Cruz argued the ALJ erred by omitting fingering or handling limits. The court held her argument rested on “an overly narrow interpretation of the term ‘manipulative limitations.’” Under Social Security Ruling (SSR) 85-15 and SSR 96-8p, reaching and handling are both subcategories of manipulative activities. Thus, “the ALJ’s inclusion of limitations regarding reaching was a type of manipulative limitation” addressed by “no overhead reaching bilaterally.”
• Reported hand pain without a medical opinion did not require hand limits. The physical therapy note cited by the ALJ addressed cervical range of motion and shoulder strength and was “silent regarding functional limitations regarding hands.” Critically, “no medical source opined that Plaintiff had limitations regarding handling, fingering, or feeling”—a point Ms. Cruz did not dispute. Treatment notes recording hand-pain complaints did not show error under the substantial-evidence standard.
• The counselor’s checkbox opinion conflicted with same-month mental status notes. For post-March 27, 2017 claims, the agency eliminated the former “treating source rule” and “will not defer or give any specific evidentiary weight, including controlling weight, to any medical opinion(s)” under 20 C.F.R. §§ 404.1520c and 416.920c, evaluating supportability and consistency instead. The ALJ found LMHC Peluffo’s opinion unpersuasive because it was “provided in a checkbox format with no meaningful explanation for most of the specific limitations assessed.” On supportability, “Peluffo’s own treatment notes did not support her opinion”: during the same month the opinion issued, Ms. Cruz “presented with relatively unremarkable mental status”—including intact memory, good attention and concentration, fair insight and judgment, and “intact functional status.” On consistency, reading the decision as a whole under Raper v. Commissioner of Social Security, 89 F.4th 1261 (11th Cir. 2024), the ALJ also noted the opinion conflicted with a consultative examination.

What this means if you have a Social Security disability claim

This Order is a single, non-binding district-court decision, and every claim turns on its own record. It does not predict how any other case will come out. Still, it illustrates several practical points:

• Distinguish reaching limits from hand-use limits. Because Social Security rulings group reaching, handling, fingering, and feeling as “manipulative” functions, a reference to manipulative limits may result only in an overhead-reaching restriction unless the record establishes handling or fingering deficits.
• Symptom reports must be evaluated with the full record. Notes recording hand pain may not establish handling or fingering limits where, as in Cruz, no medical source assessed those restrictions and the other evidence supported the RFC.
• Checkbox forms need explanation and matching notes. Under post-2017 rules, unexplained checkbox forms that conflict with “relatively unremarkable mental status” entries in contemporaneous notes are vulnerable on review.

A federal lawsuit challenging a final Social Security decision generally must be filed within 60 days after the Appeals Council’s notice is received; receipt is presumed five days after the notice date absent a reasonable showing to the contrary, and the Appeals Council may extend the period for good cause. See 42 U.S.C. § 405(g); 20 C.F.R. § 422.210(c). For an overview of the appeals process, see our Social Security disability guide. More rulings are collected on our Case Law & Industry Insights page.

If your disability claim was denied, Louis Law Group offers a free case evaluation.

Source: Order, Doc. 12, Cruz v. Commissioner of Social Security, Case No. 5:26-cv-00134-PRL (M.D. Fla. Nov. 5, 2026). This article summarizes a court ruling for general information and is not legal advice. Last updated November 7, 2026.