Justia Public Benefits Opinion Summaries
Articles Posted in U.S. Court of Appeals for the Eighth Circuit
Chaney v. Colvin
Plaintiff appealed the denial of social security disability benefits and supplemental security income. The ALJ provided valid reasons for discounting plaintiff's subjective complaints and the court held that the ALJ's less-than-fully credible determination is supported by substantial evidence; the ALJ's residual functioning capacity (RFC) is supported by substantial evidence; and the ALJ gave proper weight to plaintiff's treating physicians where the opinions were not supported by the record as a whole. Accordingly, the court affirmed the denial of benefits. View "Chaney v. Colvin" on Justia Law
Mitchael v. Colvin
Plaintiffs seek to represent a class of dual status National Guard technicians who had their benefits determined prior to the court's issuance of Petersen v. Astrue and would like to have their benefits readjusted to take advantage of the decision to avoid application of the Windfall Elimination Provision (WEP). The district court dismissed the complaint for lack of jurisdiction. The court affirmed the district court's decision to reject the application of mandamus jurisdiction where the district court held that there is no clear, nondiscretionary duty on behalf of the SSA to apply the Peterson decision to plaintiffs. The court also concluded that plaintiffs failed to present a colorable constitutional claim on equal protection grounds that would justify the application of the exception to 42 U.S.C. 405(g)’s jurisdictional limitations. Plaintiffs’ due process claim also does not support application of an exception to 405(g). Accordingly, the court affirmed the judgment. View "Mitchael v. Colvin" on Justia Law
Lawson v. Colvin
Plaintiff appealed the denial of disability insurance benefits and supplemental security income, contending that the ALJ failed to properly weigh certain medical opinions in the record. The court concluded that the ALJ did not err in discussing, reviewing or giving less weight to plaintiff's primary treating psychiatrist's opinion. In this case, the ALJ noted that the psychiatrist's opinion was inconsistent with the totality of the medical evidence and not supported by petitioner’s demonstrated level of functioning. Further, the court concluded that the ALJ properly explained her reasons for giving little weight to the “other” medical sources, and the ALJ did not err in finding the totality of the medical evidence and plaintiff's demonstrated level of functioning were inconsistent with these “other” medical sources’ opinions. Accordingly, the court affirmed the judgment. View "Lawson v. Colvin" on Justia Law
Crawford v. Colvin
Plaintiff appealed the denial of supplemental security income (SSI) where the ALJ found that plaintiff was not disabled because he could perform sedentary work. The court concluded that the ALJ correctly gave less weight to the nurse practitioner's medical opinion where it was inconsistent with other opinions from plaintiff's treating physicians. Further, the ALJ did not err by failing to obtain vocational expert testimony and instead relying solely on the Medical-Vocational Guidelines. Accordingly, the court affirmed the judgment. View "Crawford v. Colvin" on Justia Law
Cypress v. Colvin
Plaintiff appealed the denial of supplemental security income (SSI) and disability insurance benefits (DIB). The court concluded that there is no proof that the ALJ did not consider the nurse practitioner's opinion as an "other" medical source; the ALJ rightly disregarded the nurse practitioner's opinion that plaintiff was unable to work because that involves an issue reserved for the Commissioner and is not the type of "medical opinion" to which the Commissioner gives controlling weight; and the ALJ's determination of plaintiff's residual functioning capacity (RFC) that she could perform the standing and walking requirements of light work is supported by substantial evidence. Further, substantial evidence supports the ALJ's decision to not include additional manipulative limitations. Accordingly, the court affirmed the district court's order upholding the denial of SSI and DIB benefits. View "Cypress v. Colvin" on Justia Law