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

Articles Posted in Public Benefits
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The Eighth Circuit affirmed the district court's order affirming the Social Security Administration's denial of plaintiff's claim for disability benefits. Plaintiff filed a claim for a period of disability, disability insurance benefits, and supplemental security income based on her diagnoses of mood disorders, lupus, and fibromyalgia, among other ailments.The court concluded that substantial evidence in the record supported the ALJ's denial of plaintiff's claim for benefits. In this case, the ALJ did not err by relying exclusively on the lack of objective evidence supporting plaintiff's fibromyalgia diagnosis to deny benefits. Rather, the ALJ noted that objective findings did not support her subjective allegations of disabling symptoms. Likewise, the court rejected plaintiff's claims that the ALJ erred in disregarding evidence of her moderate-severe musculoskeletal pain and widespread arthralgia, as well as the multidimensional health assessment questionnaire indicating that she had difficulty performing daily tasks. The court explained that there was substantial evidence in the record for the ALJ to focus on the "normal" reports and findings by plaintiff's treating physicians. Even if the ALJ made some misstatements in his order, the errors were harmless.The court also concluded that the district court did not err in failing to develop the record to clarify the number of tender points where any inconsistences were harmless error. The court further concluded that the ALJ's credibility determination and weight assigned to the testimony was supported by undisputed facts that plaintiff suffered from addiction, smoked, and failed to follow her treatment advice. Finally, the ALJ properly considered plaintiff's allegations of pain and properly weighed the decisions of her treating physicians and state agency consultant's opinions. View "Grindley v. Kijakazi" on Justia Law

Posted in: Public Benefits
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The Eighth Circuit reversed the district court's decision affirming the ALJ's termination of plaintiff's disability insurance benefits and supplemental security income, because substantial evidence does not support the termination of benefits. In this case, plaintiff alleged that her disability began in July 2012 due to degenerative disc disease (DDD), bulging disc, irritable bowel syndrome, depression, anxiety, bipolar disorder, and post-traumatic stress disorder (PTSD).The court concluded that substantial evidence on the record as a whole does not support the finding that plaintiff's pain significantly improved to the point where she would no longer miss two days or more of work per month. In this case, the ALJ erroneously discounted plaintiff's allegations regarding her pain and also erroneously discounted other physicians' opinions. Finally, the court concluded that substantial evidence did not support the residual functioning capacity finding. The court remanded with instructions to return the case to the Social Security Administration for a new medical-improvement evaluation. View "Koch v. Kijakazi" on Justia Law

Posted in: Public Benefits
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The Eighth Circuit affirmed the district court's order upholding the Social Security Administration's denial of plaintiff's benefits claim, because substantial evidence supports the finding that the SSA has met its burden. The court concluded that the Vocational Expert relied on sufficient evidence, such as plaintiff's own testimony, when he formed his expert opinion. The court also concluded that the evidence supports the ALJ's finding that plaintiff can transfer her job skills to new sedentary positions, such as the suggested positions of order clerk, receptionist, or appointment clerk. Furthermore, there is sufficient evidence in the record to show that plaintiff possessed job skills that would transfer to other sedentary occupations. View "Swedberg v. Saul" on Justia Law

Posted in: Public Benefits
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The Eighth Circuit affirmed the denial of disability insurance benefits and supplemental social security income to plaintiff. The court held that substantial evidence supported the ALJ's decision to give little weight to plaintiffs' treating physicians because their opinions were vague and imprecise and did not provide any function-by-function analysis. Furthermore, substantial evidence supports the ALJ's decision to give greater weight to the medical consultants' opinions than to the treating physicians' opinions.Finally, the vocational expert's answer to the first hypothetical question, regarding whether a hypothetical person—who could lift amounts that plaintiff could, sit and stand for periods that she could, and work in a workplace devoid of fumes that irritated her—could work, is substantial evidence because it is a response to a hypothetical with the impairments accepted as true by the ALJ and reflected in the residual functional capacity (RFC). However, the vocational expert's answer to the second hypothetical question, regarding whether a hypothetical person with the impairments plaintiff alleged could work, was not substantial evidence because the hypothetical person in the second hypothetical did not have the same RFC as plaintiff. View "Kraus v. Saul" on Justia Law

Posted in: Public Benefits
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The Eighth Circuit affirmed the denial of social security benefits to plaintiffs, rejecting plaintiffs' claim that the ALJs who denied their claims were not properly appointed under the Appointments Clause of the Constitution. The court held that plaintiffs' unexhausted claims are foreclosed by Davis v. Saul, 963 F.3d 790 (8th Cir. 2020), cert. granted, 2020 WL 6551772 (Nov. 9, 2020) (No. 20-105). View "Smith v. Saul" on Justia Law

Posted in: Public Benefits
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The Eighth Circuit affirmed the district court's dismissal of plaintiff's challenge to the Commissioner's denial of her application for disability insurance benefits and supplemental security income. The court held that substantial evidence supported the ALJ's determination concerning the limits of plaintiff's ability to reach and handle throughout an otherwise sedentary workday. In this case, one of the jobs cited by the vocational expert as available in the national economy—call out operator—requires only occasional, rather than frequent, handling. Therefore, the identified job is even less demanding on plaintiff's upper extremities than would be permitted by the Commissioner's residual functional capacity limitation. View "Lawrence v. Saul" on Justia Law

Posted in: Public Benefits
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Independent of the Individuals with Disabilities Education Act (IDEA), Minnesota has adopted an "open enrollment" process that allows a parent to enroll a student in a school outside of the student's local district.The Eighth Circuit held that the IDEA does not require a school district that enrolls a nonresident student like M.N.B. to provide transportation between the student's home and the school district where her parent has chosen to enroll her. The court saw nothing in the IDEA that provides clear notice to a state that it must cover transportation expenses when a student's travel is the result of a parent's choice under an open enrollment program. Therefore, under the circumstances presented here, the court concluded that the IDEA does not require the Osseo District to reimburse M.N.B.'s parent for the cost of transportation between her home and the border of the Osseo District. The court reversed the district court's grant of summary judgment in favor of M.N.B. View "Osseo Area Schools v. M.N.B." on Justia Law

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The Eighth Circuit affirmed the denial for disability insurance benefits and supplemental security income to plaintiff. The court held that the ALJ properly weighed the opinions of medical professionals, including a physician's assistant, and gave partial weight to the opinion of a certain medical expert. The court also held that sufficient evidence in the record supported the ALJ's decision, including clinical notes that plaintiff lost weight from moving around so much, left a clinical appointment with a brisk walk and no cane, and stated he was doing well after a total hip replacement. Finally, the court held that a hypothetical question given to the vocational expert captured the concrete consequences of plaintiff's impairments, and the court need not consider plaintiff's Appointments Clause challenge. View "Hilliard v. Saul" on Justia Law

Posted in: Public Benefits
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The Eighth Circuit reversed the district court's dismissal of a petition for review of the Commissioner's denial of plaintiff's application for disability insurance benefits and supplemental security income. The court held that, although the record provides ample support for determinations regarding the severity and limiting effect of most of plaintiff's impairments, further development is required as to the functional limitations on walking and standing. Therefore, the court remanded for further proceedings. View "Noerper v. Saul" on Justia Law

Posted in: Public Benefits
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Plaintiffs each brought an action asserting that the ALJ who denied their application for benefits was not properly appointed in accordance with the Appointments Clause of the Constitution.The Eighth Circuit held that the district court properly declined to consider the issue and affirmed the judgments. In these cases, none of the claimants raised the issue during the proceedings before the Social Security Administration and thus the district court properly concluded that they waived their argument. The court rejected plaintiffs' claims that their constitutional claims need not be exhausted and that exhaustion of this particular constitutional challenge would have been futile. The court further explained that this is not one of the rare situations in which a federal court should consider an issue that was not presented to the agency. View "Davis v. Saul" on Justia Law

Posted in: Public Benefits