Articles Posted in Public Benefits

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The Eighth Circuit affirmed the Commissioner's denial of disability benefits and dismissal of plaintiff's complaint under 42 U.S.C. 405(g). The court held that the record overwhelmingly supported the determination that plaintiff was not disabled, and the court found no legal error in the ALJ's analysis. In this case, plaintiff was a stay-at-home father married to a physician; he cared for and transported his four young children, performed housekeeping tasks, managed the sale of the family's house, and negotiated with the builders of a new house; and the record demonstrated that not only did he participate in these varied activities, but that he was able to navigate the obvious stresses inherent in these activities when compliant with his prescribed medications. The court held that the ALJ's statements in the step-two and three analyses was not inconsistent with the ALJ's step-four Residual Functional Capacity determination. View "Chismarich v. Berryhill" on Justia Law

Posted in: Public Benefits

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The Eighth Circuit vacated the district court's decision affirming the denial of social security disability benefits to plaintiff. The court held that substantial evidence on the record as a whole supported the ALJ's decision to give plaintiff's treating physician's residual functioning capacity (RFC) assessments little weight and to rely more heavily on other opinions in the record. However, a conflict marred the expert's testimony that an individual with plaintiff's RFC could perform the work of a new accounts clerk. Therefore, the court remanded with instructions for the district court to return the case to the Social Security Administration for a new step-five determination. View "Thomas v. Berryhill" on Justia Law

Posted in: Public Benefits

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The Eighth Circuit reversed the district court's order affirming the ALJ's denial of plaintiff's application for disability insurance benefits and supplemental security income. The court held that the ALJ erred in relying on his own inferences about what plaintiff's medical providers meant when they noted in her medical records that she was in "no acute distress" and had "normal movement of all extremities" to determine her residual functioning capacity. The court explained that remand was necessary so the ALJ may conduct further inquiry as to what relevance plaintiff's being in "no acute distress" and having "normal movement of all extremities" has in terms of plaintiff's ability to function in the workplace. View "Combs v. Berryhill" on Justia Law

Posted in: Public Benefits

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The Eighth Circuit reversed the denial of disability insurance benefits (DIB) and supplemental security income (SSI), holding that substantial evidence was insufficient to support the ALJ's denial of benefits. In this case, the ALJ's residual functional capacity assessment and hypothetical question to the vocational expert (VE) did not contain all impairments supported by substantial evidence in the record, and thus the VE's testimony was not substantial evidence. View "Gann v. Berryhill" on Justia Law

Posted in: Public Benefits

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Minn. Stat. 125A.06(d), by its plain language, does not impose a heightened standard that burdens school districts with an absolute obligation to guarantee that each blind student will use the Braille instruction provided to attain a specific level of proficiency. I.Z.M. filed suit against the District, alleging claims under the Individuals with Disabilities Education Act (IDEA) and non-IDEA claims for relief under Title II of the Americans with Disabilities Act (ADA), and Section 504 of the Rehabilitation Act. The Eighth Circuit affirmed the district court's grant of the District's motions for judgment on the administrative record on the IDEA claim and for summary judgment on the non-IDEA claims. In this case, the ALJ cited the state regulation and expressly concluded that the District took all reasonable steps to provide instructional materials in accessible formats in a timely manner. In regard to the non-IDEA claims, the district court used the correct standard and correctly concluded that I.Z.M. failed to present evidence of bad faith or gross misjudgment View "I.Z.M. v. Rosemount-Apple Valley-Eagan Public Schools" on Justia Law

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The Eighth Circuit affirmed the denial of plaintiff's disability insurance benefits and supplemental security income. The court held that the ALJ clearly considered the Polaski factors in accessing plaintiff's subjective complaints and substantial evidence supported her determination that plaintiff's statements concerning her symptoms were not entirely credible. Furthermore, substantial evidence supported the ALJ's residual functioning capacity determination that plaintiff was able to perform medium work. View "Bryant v. Colvin" on Justia Law

Posted in: Public Benefits

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The Eighth Circuit affirmed the denial of plaintiff's application for supplemental security income. The court held that a reasonable mind could find that the record supports the ALJ's determination that plaintiff did not meet Listing 11.17A; the ALJ reasonably found, based on the record as a whole, that plaintiff did not exhibit the deficits in adaptive functioning needed to meet Listing 12.05C; and the ALJ had ample reason to discount the opinion of plaintiff's treating physician and to rely instead on the opinions of the state agency medical consultants, which were more consistent with the medical evidence. View "Vance v. Berryhill" on Justia Law

Posted in: Public Benefits

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The Eighth Circuit affirmed the denial of plaintiff's social security disability benefits, holding that substantial evidence supported the ALJ's decision to deny benefits. The court held that substantial evidence supported the ALJ's decision to assign little weight to the opinion of plaintiff's treating psychiatrist based on internal inconsistency and conflict with other evidence on the record; the ALJ did not err by assigning insufficient weight to the opinions of plaintiff's caseworker and Mental Health Paraprofessional (MHPP); and the ALJ's residual functioning capacity determination, as well as the other evidence in the record, reflected the limitations of plaintiff's ability to follow instructions, socialize, and maintain concentration. View "Chesser v. Berryhill" on Justia Law

Posted in: Public Benefits

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The court affirmed the denial of plaintiff's application for supplemental security income, concluding that substantial evidence supported the ALJ's decision. Substantial evidence supported the ALJ's conclusion that claimant did not meet or equal Listing 12.05C because he did not demonstrate the adaptive function limitations necessary to qualify; the ALJ adequately accounted for plaintiff's limitations in concentration persistence, or pace in the residual functional capacity; and the vocational expert's testimony constituted substantial evidence supporting the ALJ's finding at step five. View "Scott v. Berryhill" on Justia Law

Posted in: Public Benefits

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Plaintiff appealed the partial denial of his applications for disability insurance benefits (DIB) and supplemental security income (SSI). Plaintiff suffers from asthma, chronic obstructive pulmonary disease, high blood pressure, depression, hepatitis C, diabetes, liver damage, hepatomegaly, uveitis of the left eye, coronary artery disease, and degenerative disc disease. In this case, the Commissioner concluded that plaintiff was able to perform light work, with limitations, for a period of time before he became disabled under the Guidelines, after the Commissioner reviewed the entire record and considered the objective test results, plaintiff's subjective reports and complaints of pain, as well as the opinions of treating and consulting physician. The court found that the Commissioner's determination was within a reasonable "zone of choice." Because the Commissioner's decision to deny benefits prior to August 24, 2012, was supported by substantial evidence on the record as a whole, the court affirmed the judgment. View "Fentress v. Colvin" on Justia Law

Posted in: Public Benefits