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

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

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

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

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

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

Plaintiff challenged the denial of his application for disability insurance benefits. Plaintiff claims that he is disabled as a result of osteoarthritis and degenerative joint disease of the hips, degenerative disc disease of the lumbar and cervical spines, sensory and motor neuropathies, chronic shoulder pain and osteoarthritis, and carpal tunnel syndrome. The court concluded that the ALJ did not err in failing to find that plaintiff's impairments met or equaled the criteria of Listing 1.02A; substantial evidence in the record as a whole supports the ALJ’s finding that plaintiff had the residual functional capacity to perform his past relevant work as a receptionist and thus was not disabled; and the denial of disability insurance benefits is supported by substantial evidence on the record as a whole. Accordingly, the court affirmed the judgment. View "Igo v. Colvin" on Justia Law

Plaintiff appealed the denial of Social Security disability insurance benefits. The ALJ concluded that she suffered from severe but not listed impairments – mood disorder, anxiety disorder, residuals of brain tumor with surgical resection, degenerative disc disease of the thoracic and cervical spine, and scoliosis – but that plaintiff was not disabled because, while she could not perform her past relevant work, she retained the residual functional capacity (RFC) to perform a limited range of light work. In this case, the ALJ expressly incorporated into the RFC work-related limitations suggested by medical source opinions regarding plaintiff's slow pace; the cumulative evidence submitted did not undermine the ALJ's RFC determination; and the ALJ properly weighed and considered the extensive medical evidence in the record in making the RFC determination. Therefore, the court concluded that substantial evidence on the record as a whole supports the ALJ’s decision and the court affirmed the judgment. View "Harvey v. Colvin" on Justia Law

Plaintiff appealed the denial of her Social Security benefits, arguing that the ALJ's determination that she is not disabled is not supported by substantial evidence on the record as a whole. Plaintiff claimed that she was unable to work due to osteoarthritis, lumbago, a congenital back defect, chronic stomach pain, and pulmonary restrictions. The court concluded that the Commissioner gave good reasons for discounting the opinion of plaintiff's treating physician and that substantial evidence in the record as a whole supports the Commissioner’s decision that plaintiff was not disabled. Accordingly, the court affirmed the denial of benefits. View "Reece v. Colvin" on Justia Law

Plaintiff appealed the denial of her social security disability benefits. As a preliminary matter, the court concluded that neither the doctrine of collateral estoppel nor law of the case applies to plaintiff's claim. On the merits, the court concluded that there was substantial evidence in the record to support the current ALJ's decision where he considered and evaluated her treating physician's opinion (Dr. Kinney). The ALJ did discount some of the physician's opinion about plaintiff's marked limits on performing work at a consistent pace because it found the record did not support such conclusions. The court also concluded that the ALJ thoroughly considered the opinions of other treating sources (Dr. Heims and Dr. Stubblefield). Finally, substantial evidence supports the ALJ's adverse credibility finding where the ALJ discounted plaintiff's subjective complaints of pain. In this case, plaintiff had not sought treatment for some of the complained limitations, the objective medical evidence was inconsistent with several of her allegations, there was a general lack of consistent medical treatment, and she seemed to return to the doctors only when she needed disability forms filled out. Furthermore, plaintiff was noncompliant with suggestions by her own treating physician. Accordingly, the court affirmed the judgment. View "Aguiniga v. Colvin" on Justia Law

Plaintiff appealed the denial of supplemental security income (SSI) and disability insurance benefits (DIB). Plaintiff alleged disability due to diabetes mellitus, heart problems, fatigue, and chest, back and leg pain. The court concluded that substantial evidence supports the ALJ's finding that plaintiff has the residual functioning capacity to perform sedentary work; the ALJ properly discounted the opinion of plaintiff's physician, Dr. Johnson, based upon lack of support in the examination record; the ALJ adequately explained that he discounted plaintiff's description of limited daily activities because it could not be adequately verified, was inconsistent with the “relatively weak medical evidence,” and was not supported by corresponding specific restrictions on activities imposed by a treating physician; and the ALJ did not err in accepting the testimony of the vocational expert where the testimony constituted substantial evidence to support the ALJ's finding at step five of the sequential evaluation process. Accordingly, the court affirmed the judgment. View "Boyd v. Colvin" on Justia Law