Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Plaintiff appealed the denial of his application for social security disability insurance (SSDI). Plaintiff alleged that the ALJ erred by failing to order an intelligence quotient (IQ) test, evaluating plaintiff's intellectual capacity, and accepting a vocational expert's assessment. Without an essential IQ test, the ALJ could not make an informed choice about whether plaintiff's mild mental retardation met listing 12.05C. The court concluded that plaintiff must be afforded an IQ test and a reevaluation of his disability applications. Accordingly, the court reversed and remanded with directions to further develop the record. View "Lott, Jr. v. Colvin" on Justia Law

Plaintiff appealed the denial of her application for supplemental security income (SSI) where she alleged that she was disabled due to back pain, scoliosis, and other conditions. The court concluded that the Commissioner did not err in affording little weight to plaintiff's treating physician's opinion because it was inconsistent with the treatment records and the objective medical evidence as a whole, and was not supported by the physician's own physical examination of plaintiff and the objective test results. Therefore, the court concluded that substantial evidence in the record as a whole supported the Commissioner's decision that plaintiff was not disabled. Accordingly, the court affirmed the denial of benefits. View "Cline v. Colvin" on Justia Law

Plaintiff appealed the denial of her application for disability insurance benefits, asserting that she had difficulty breathing and painful joints. The court concluded that the ALJ did not err in giving greater weight to a medical expert's testimony than to the testimony of other experts; the ALJ did not err in not seeking clarifications to plaintiff's expert's opinion where the ALJ expressly refused to give the expert opinion "great weight" and then explaining its reasons for doing so; the ALJ's decision was based on substantial evidence; the ALJ considered plaintiff's obesity and made findings about the demands of her prior work as a file clerk; and the ALJ did not err in relying on the vocational expert's testimony that plaintiff's mental and physical condition, age, and education support her ability to perform "unskilled occupations." Accordingly, the court affirmed the denial of benefits. View "Grable v. Colvin" on Justia Law

Plaintiff appealed the denial of her application for social security disability insurance benefits, alleging total disability due to, among other things, depression, anxiety, joint deterioration, and swelling in her hands and feet. The court held that substantial evidence, including contemporaneous treatment notes, independent medical opinions, and plaintiff's own behavior, supported the ALJ's and the district court's determination that she could perform sedentary work. Accordingly, the court affirmed the judgment.View "Ponder v. Colvin" on Justia Law

Plaintiff appealed the denial of his applications for Social Security disability insurance benefits and supplemental security income. The court concluded that the ALJ's determination is supported by substantial evidence on the record that a person with plaintiff's residual functional capacity can perform a sufficient number of existing jobs based on the vocational expert's testimony. Accordingly, the court affirmed the judgment of the district court.View "Gieseke v. Colvin" on Justia Law

Plaintiff appealed the denial of his application for supplemental security income where the ALJ found that plaintiff was not disabled because he could perform jobs a vocational expert (VE) identified in response to a hypothetical posed by the ALJ. The court agreed with plaintiff that the ALJ failed to resolve an apparent conflict between the physical limitations described by the ALJ in his hypothetical and the requirements of the jobs the VE identified, as listed in the Dictionary of Occupational Titles. Accordingly, the court vacated and remanded for further proceedings.View "Moore, Jr. v. Colvin" on Justia Law

Plaintiff appealed the denial of his application for Social Security disability and supplemental security income benefits. The court concluded that the ALJ's failure to explicitly refer to SSR 96-9p was an arguable deficiency in opinion writing that had no practical effect on the decision and therefore was not a sufficient reason to set aside the ALJ's decision; the ALJ posed a hypothetical that accurately reflected his residual functioning capacity (RFC) finding, questioned the vocational expert (VE) about any apparent inconsistencies with the relevant DOT job descriptions, explained his decision to credit the VE's testimony, and, therefore, the ALJ complied with SSR 00-4p; and substantial evidence supported the ALJ's finding that a sufficient number of jobs existed in the national and local economies that a person with plaintiff's RFC could perform, based on the VE's testimony. Accordingly, the court affirmed the judgment of the district court.View "Welsh v. Colvin" on Justia Law

Relator filed a qui tam action against Planned Parenthood, alleging that it violated the False Claims Act (FCA), 31 U.S.C. 3729-3733, and the Iowa False Claims Act (IFCA), Iowa Code Ann. 685.1-.7, by submitting false or fraudulent claims for Medicaid reimbursement. The district court dismissed the complaint under Rule 9(b). The court concluded that relator has pled sufficiently particularized facts to support her allegations that Planned Parenthood violated the FCA by filing claims for (1) unnecessary quantities of birth control pills, (2) birth control pills dispensed without examinations or without or prior to a physician's order, (3) abortion-related services, and (4) the full amount of services that had already been paid, in whole or in part. The court affirmed the dismissal of relator's claim that Planned Parenthood violated the FCA by instructing patients who experienced abortion-related complications to give false information to medical professionals at other hospitals, causing those medical professionals to unknowingly file claims for services performed in connection with abortions. Because relator failed to provide a factual basis for her knowledge of these alleged false claims, the court was unable to infer that false claims were submitted. Further, the court affirmed the dismissal of relator's upcoding claim. The court's holding with respect to the Rule 9(b) issue, however, should not be read as in any way expressing a view on Planned Parenthood's Rule 12(b)(6) arguments.View "Thayer v. Planned Parenthood" on Justia Law

Plaintiffs filed suit on behalf of themselves and a class, alleging a miscalculation of their Medicare Part B premium calculations. Plaintiffs conceded that they failed to exhaust administrative remedies. Because this case is not one of the exceptional cases where waiver of exhaustion is appropriate, the court affirmed the district court's determination that it lacked subject matter jurisdiction. The court affirmed the judgment of the district court on this issue and affirmed the district court's denial of mandamus relief where plaintiffs may pursue another avenue of relief, the administrative process.View "Degnan, et al. v. Sebelius, et al." on Justia Law

Plaintiff appealed the denial of disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. 401-434. The court agreed with the district court that the ALJ properly articulated his reasons for granting little weight to plaintiff's physician's opinions, and for finding the physician's opinions to be inconsistent with the record as a whole; that the ALJ properly considered plaintiff's medical records, observations of treating physicians, and plaintiff's own description of his limitations in making the residual functional capacity (RFC) assessment for plaintiff; and that the ALJ made a proper RFC determination based on a fully and fairly developed record. The court also concluded that substantial evidence exists in the record to support the ALJ's adverse credibility finding, and the district court did not abuse its discretion by failing to remand for reconsideration under 42 U.S.C. 405(g). Accordingly, the court affirmed the judgment of the district court. View "Whitman v. Colvin" on Justia Law