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

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

After plaintiff suffered a serious knee injury while deployed by the Army in Iraq combat, he underwent surgery and the VA awarded him benefits for service-connected disability. Plaintiff then applied for Social Security disability insurance benefits for post-traumatic stress disorder (PTSD), back pain, right knee pain, and facial twitching. On appeal, plaintiff challenged the denial of disability benefits. The court concluded that substantial evidence on the administrative record supports the ALJ's conclusion that defendant retained the residual functioning capacity (RFC) to perform certain sedentary work during the relevant period at issue; the ALJ could reasonably conclude that plaintiff's repeated failure to attend a prescribed course of treatment was evidence that his mental impairment was less disabling than defendant claimed; and the ALJ explicitly acknowledged the VA’s disability finding, and correctly noted that the disability finding of another agency like the VA was not binding on the Social Security Administration. Accordingly, the court affirmed the judgment. View "Hensley v. Colvin" on Justia Law

Plaintiff appealed the denial of her application for supplemental security income. Plaintiff based her claims of disability on depression, anxiety, and obsessive-compulsive disorder. Plaintiff alleged that these conditions caused her difficulties with maintaining focus, energy, concentration, social interactions, and a regular schedule. The court concluded that the ALJ properly discounted plaintiff's credibility; the ALJ gave good reasons for the weight accorded to the medical evidence where the ALJ was entitled to discount the opinions of plaintiff's treating physician insofar as they relied on plaintiff's subjective complaints; and sufficient medical evidence supports the ALJ's determination of residual functional capacity. Accordingly, the court affirmed the judgment. View "Julin v. Colvin" on Justia Law

Plaintiff appealed the denial of his application for disability insurance benefits, alleging disability beginning in November 2011 due to severe hearing loss, diabetes, diabetic neuropathy, chronic obstructive pulmonary disease, degenerative disc disease of the lumbar spine, and severe diarrhea caused by medication side effects. The court reversed and remanded, finding that the ALJ did not mention, much less resolve, the seemingly inconsistent results obtained from plaintiff's two hearing tests. Nor did the ALJ adequately explain why he apparently elected to place greater weight on the results from the April 2012 hearing test rather than the results from the February 2012 hearing test. Neither test was deemed to be altogether reliable. This factor, coupled with the ALJ’s failure to accurately describe the medical evidence in the record and his failure to identify or analyze the relevant Listing, lead the court to determine that the ALJ's finding was not supported by substantial evidence. View "Brown v. Colvin" on Justia Law

Plaintiff alleged a disability due to gout, arthritis, back pain, diabetes, high blood pressure, and obesity. In this appeal, he challenged the denial of his application for disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. 405. The ALJ found that plaintiff was capable of performing his past relevant work as a farm worker. The court concluded that the ALJ's determination that plaintiff's residual functioning capacity (RFC) to do medium work, with some limitations, is supported by substantial evidence and that the ALJ sufficiently developed the record. In this case, the objective medical findings do not support the degree of limitation alleged by plaintiff. Finally, the court rejected plaintiff's contention that the ALJ failed to adequately develop the record. Accordingly, the court affirmed the judgment. View "Buford v. Colvin" on Justia Law

Plaintiff, who suffers from Ehlers-Danlos Syndrome, filed suit against the Department after it denied him "shelter needy" benefits, raising claims under 42 U.S.C. 1983; the Americans with Disabilities Act (ADA), 12 U.S.C. 12101 et seq.; and the Rehabilitation Act (RA), 29 U.S.C. 701 et seq. The court concluded that the appeal was timely, rejecting the district court's conclusion that plaintiff did not timely file notice and proof of service; concluded that the Rooker-Feldman doctrine is inapplicable to judicial review of executive action, including determinations made by a state administrative agency; and disagreed with the district court’s conclusion that section 256.045 of the Minnesota statutes prevented the court from exercising supplemental jurisdiction over the appeal from a state agency’s decision. In interpreting Minn. Stat. 256.045, subd. 7, the court concluded that subdivision 7 lays out one permissible route through which an aggrieved party may appeal from the Commissioner’s order and thus prevent it from becoming final, but it does not strip the federal court of its authority to hear the same appeal through the exercise of supplemental jurisdiction. Because the district court improperly concluded that it lacked jurisdiction based solely on the state statute, the district court failed to determine whether it should exercise supplemental jurisdiction under 28 U.S.C. 1367 or whether any abstention doctrine applied. Therefore, the court vacated the decision dismissing the supplemental state-law claim and remanded for further consideration. Because the state agency’s decision was not final, the district court erred by finding that plaintiff’s ADA and RA claims were precluded. Finally, the court agreed with the district court that plaintiff's allegations failed to state a due process or equal protection claim. Because plaintiff’s equal protection claim is predicated on the same allegations as his ADA and RA claims, the district court did not err by dismissing the section 1983 claim. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Wong v. Minnesota DHS" on Justia Law

Robert Dean Carter appealed the denial of his application for disability insurance benefits and supplemental security income. The ALJ concluded that Carter was not disabled because he did not have an impairment or combination of impairments that met or medically equaled one of the listed impairments for chronic heart failure and because Carter had the residual functional capacity (RFC) to perform a limited range of sedentary work. After Carter died, Carter's daughter, KKC, appealed the denial of benefits. The court concluded that substantial evidence supports the ALJ’s finding that Carter’s impairment did not meet section 4.02(B)(1) and 4.02(B)(3); the ALJ did not err by refusing to give controlling weight to the opinion of Carter's treating physician where the physician's statement at issue did not resolve the legal issue of whether Carter was disabled; and the ALJ’s RFC assessment was supported by substantial evidence on the record as a whole. Accordingly, the court affirmed the judgment. View "KKC v. Colvin" on Justia Law

SEARK, operator of two hospice-care facilities, voluntarily entered into a provider agreement with the Secretary of Health and Human Services to receive Medicare reimbursement pursuant to the Medicare Act, 42 U.S.C. 1395c, 1395f(a)(7), 1395cc. The Act annually caps Medicare reimbursement. SEARK filed suit after the Secretary sent it seven demands for repayment, arguing that the cap violates the Takings Clause of the Fifth Amendment. The district court concluded that SEARK’s voluntary participation in the Medicare program precludes a takings claim. The court concluded that SEARK has not met its burden to prove the demands for repayment based on the statutory cap are a taking where the reimbursement cap allocates the government's capacity to subsidize healthcare; SEARK presented no evidence to suggest the cap makes it impossible to profitably engage in their business; and SEARK voluntarily chose to participate in the Medicare hospice program. Accordingly, the court affirmed the judgment. View "Southeast Arkansas Hospice v. Burwell" on Justia Law

Plaintiff, complaining of right-shoulder and arm pain, appealed the denial of his application for disability benefits. The court concluded that the ALJ's denial of benefits is supported by substantial evidence because plaintiff has the residual functioning capacity (RFC) to perform sedentary work, and the ALJ limited plaintiff to work involving no overhead reaching with his right arm. Further, the medical evidence supports the RFC. Accordingly, the court affirmed the judgment. View "Liner v. Colvin" on Justia Law