Articles Posted in US Court of Appeals for the Eighth Circuit

by
The Eighth Circuit reversed the district court's decision upholding the Social Security Commission's denial of plaintiff's applications for child insurance benefits and supplemental security income. The court held that the ALJ did not elicit a reasonable explanation to resolve an apparent conflict between testimony from the vocational expert and the Dictionary of Occupational Titles (DOT) when it determined that plaintiff's limitations did not prevent him from performing certain jobs in the national economy. In this case, the conflict was in regard to the DOT's listing related to the level of reasoning required for the job of hospital or industrial cleaner. Accordingly, the court remanded for further proceedings. View "Stanton v. Commissioner" on Justia Law

by
The Eighth Circuit affirmed the district court's denial of social security disability benefits to plaintiff. The court held that the ALJ properly relied on testimony from the vocational expert's testimony that a certain needed modification is part of the functional workplace. In this case, the vocational expert testified based on her expertise that bariatric chairs were commonly provided to individuals in the workplace and identified jobs that an individual who, like plaintiff, needs a bariatric chair, could perform. Therefore, substantial evidence supported the ALJ's finding that jobs exist in the national economy that plaintiff could adjust to, and that finding did not result from an error of law. View "Higgins v. Commissioner" on Justia Law

by
The Eighth Circuit affirmed the denial of plaintiff's claims for a period of disability, disability insurance benefits, and supplemental security income. The court held that Social Security Ruling (SSR) 00-4p makes clear that before relying on Vocation Expert (VE) evidence, adjudicators must identify and obtain a reasonable explanation for any conflicts between such evidence and the DOT. However, SSR 00-4p did not impose a duty on the ALJ to obtain a reasonable explanation when the VE simply testifies to information not found in the DOT—but that does not conflict with it. Therefore, the court agreed with the Commissioner that unless a VE's testimony appears to conflict with the DOT, there is no requirement that an ALJ inquire as to the precise basis for the expert's testimony regarding extra-DOT information. In this case, the ALJ described plaintiff's limitations to the VE, the VE responded with possible jobs, and the VE's testimony did not conflict with the DOT. Therefore, the ALJ was entitled to rely on the testimony and substantial evidence supported the agency's finding that plaintiff was not disabled. View "Courtney v. Commissioner" on Justia Law

by
The Eighth Circuit affirmed the denial of social security disability insurance benefits on remand. The court held that the ALJ did not err in discounting the opinion of plaintiff's treating physician as not supported by objective medical evidence in the administrative record. Furthermore, the opinion was contrary to medically supported opinions of two specialists. The court agreed with the district court that the vocational expert identified another job plaintiff could perform with limited hand functioning, and there was nothing in the record suggesting that his impairments require that he be limited to occasional rather than frequent handling. View "Winn v. Commissioner" on Justia Law

by
The Eighth Circuit affirmed the Commissioner's denial of disability benefits and dismissal of plaintiff's complaint under 42 U.S.C. 405(g). The court held that the record overwhelmingly supported the determination that plaintiff was not disabled, and the court found no legal error in the ALJ's analysis. In this case, plaintiff was a stay-at-home father married to a physician; he cared for and transported his four young children, performed housekeeping tasks, managed the sale of the family's house, and negotiated with the builders of a new house; and the record demonstrated that not only did he participate in these varied activities, but that he was able to navigate the obvious stresses inherent in these activities when compliant with his prescribed medications. The court held that the ALJ's statements in the step-two and three analyses was not inconsistent with the ALJ's step-four Residual Functional Capacity determination. View "Chismarich v. Berryhill" on Justia Law

by
The Eighth Circuit affirmed the Commissioner's denial of disability benefits and dismissal of plaintiff's complaint under 42 U.S.C. 405(g). The court held that the record overwhelmingly supported the determination that plaintiff was not disabled, and the court found no legal error in the ALJ's analysis. In this case, plaintiff was a stay-at-home father married to a physician; he cared for and transported his four young children, performed housekeeping tasks, managed the sale of the family's house, and negotiated with the builders of a new house; and the record demonstrated that not only did he participate in these varied activities, but that he was able to navigate the obvious stresses inherent in these activities when compliant with his prescribed medications. The court held that the ALJ's statements in the step-two and three analyses was not inconsistent with the ALJ's step-four Residual Functional Capacity determination. View "Chismarich v. Berryhill" on Justia Law

by
The Eighth Circuit vacated the district court's decision affirming the denial of social security disability benefits to plaintiff. The court held that substantial evidence on the record as a whole supported the ALJ's decision to give plaintiff's treating physician's residual functioning capacity (RFC) assessments little weight and to rely more heavily on other opinions in the record. However, a conflict marred the expert's testimony that an individual with plaintiff's RFC could perform the work of a new accounts clerk. Therefore, the court remanded with instructions for the district court to return the case to the Social Security Administration for a new step-five determination. View "Thomas v. Berryhill" on Justia Law

by
The Eighth Circuit reversed the district court's order affirming the ALJ's denial of plaintiff's application for disability insurance benefits and supplemental security income. The court held that the ALJ erred in relying on his own inferences about what plaintiff's medical providers meant when they noted in her medical records that she was in "no acute distress" and had "normal movement of all extremities" to determine her residual functioning capacity. The court explained that remand was necessary so the ALJ may conduct further inquiry as to what relevance plaintiff's being in "no acute distress" and having "normal movement of all extremities" has in terms of plaintiff's ability to function in the workplace. View "Combs v. Berryhill" on Justia Law

by
The Eighth Circuit reversed the denial of disability insurance benefits (DIB) and supplemental security income (SSI), holding that substantial evidence was insufficient to support the ALJ's denial of benefits. In this case, the ALJ's residual functional capacity assessment and hypothetical question to the vocational expert (VE) did not contain all impairments supported by substantial evidence in the record, and thus the VE's testimony was not substantial evidence. View "Gann v. Berryhill" on Justia Law

by
Minn. Stat. 125A.06(d), by its plain language, does not impose a heightened standard that burdens school districts with an absolute obligation to guarantee that each blind student will use the Braille instruction provided to attain a specific level of proficiency. I.Z.M. filed suit against the District, alleging claims under the Individuals with Disabilities Education Act (IDEA) and non-IDEA claims for relief under Title II of the Americans with Disabilities Act (ADA), and Section 504 of the Rehabilitation Act. The Eighth Circuit affirmed the district court's grant of the District's motions for judgment on the administrative record on the IDEA claim and for summary judgment on the non-IDEA claims. In this case, the ALJ cited the state regulation and expressly concluded that the District took all reasonable steps to provide instructional materials in accessible formats in a timely manner. In regard to the non-IDEA claims, the district court used the correct standard and correctly concluded that I.Z.M. failed to present evidence of bad faith or gross misjudgment View "I.Z.M. v. Rosemount-Apple Valley-Eagan Public Schools" on Justia Law