Articles Posted in US Court of Appeals for the Eighth Circuit

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The Eighth Circuit affirmed the denial of social security disability insurance benefits and supplemental security income (SSI) benefits to claimant. The court held that substantial evidence supported the ALJ's findings that claimant's physical and mental impairments did not meet or equal the severity of any of the listed impairments. Furthermore, substantial evidence supported the ALJ's residual functioning capacity determination and the mental limitations included in that finding. The court also held that the vocational expert's testimony did not conflict with the Dictionary of Occupational Titles and the ALJ was entitled to rely on the expert's testimony. View "Twyford v. Commissioner" on Justia Law

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The Eighth Circuit affirmed the denial of social security disability benefits to claimant, holding that the denial of benefits was supported by substantial evidence. The court held that the ALJ did not err in determining claimant's Residual Functional Capacity and did not err in determining that the medical records did not support the limitations stated by her treating physician. The court also held that the ALJ did not err by discrediting the physician's testimony to the extent that it exceeded the supported limitations. View "Despain v. Berryhill" on Justia Law

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The Eighth Circuit affirmed the denial of disability insurance benefits to claimant. The court held that the agency was justified in reopening claimant's case based on new and material information; there was no due process violation and claimant had adequate notice that the reopened proceedings could result in a determination that she was not disabled; res judicata did not bar the Commissioner from revising a determination; substantial evidence supported the ALJ's determination that claimant was not disabled from 2012 onward; claims of witness and evidentiary errors rejected; the ALJ did not err in determining that claimant could perform her past relevant work; and there was no error in the ALJ's statement regarding claimant's residual functional capacity (RFC) to the vocational expert where substantial evidence supported the omission of certain limitations from her RFC. View "Schwandt v. Berryhill" on Justia Law

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The Eighth Circuit affirmed the district court's dismissal of plaintiff's action challenging the denial of his application for disability insurance benefits. The court held that plaintiff was not entitled to equitable tolling of the time limit, because no extraordinary circumstance prevented him from timely filing an action in the district court. In this case, plaintiff's failure to file his appeal despite clear, repeated instructions that he should do so, was at best a garden variety claim of excusable neglect for which equitable tolling was unavailable. Therefore, plaintiff's action was time-barred and was properly dismissed by the district court. View "Thompson v. Commissioner of Social Security Administration" on Justia Law

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The Eighth Circuit affirmed the denial of disability benefits to plaintiff based on his claim of mild intellectual disability, low education, slow learning abilities, and memory problems. The court held that substantial evidence supported the ALJ's assessment that plaintiff was only moderately intellectually limited, rather than intellectually disabled. Consequently, the court also held that plaintiff's claim that the ALJ failed to consider whether plaintiff met the criteria for intellectual disability was meritless. View "Bagwell v. Commissioner" on Justia Law

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The Eighth Circuit reversed and remanded the district court's denial of disability insurance benefits and supplemental security income to plaintiff. The court held that the ALJ failed to provide a good reason for disregarding the treating physician's opinion when, after noting that the patient's subjective complaints formed the basis for the doctor's opinion, the ALJ stated only that she declined to accept portions of the treating physician's functional capacities assessment. View "Walker v. Commissioner, Social Security Administration" on Justia Law

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The district court affirmed the denial of social security disability benefits to claimant, holding that substantial evidence supported the ALJ's finding that claimant had the residual functional capacity to perform sedentary work. In this case, the ALJ did not err by discounting the treating physician's opinions because they conflicted with claimant's treatment records. View "Adkins v. Commissioner, Social Security Administration" on Justia Law

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The Eighth Circuit affirmed the denial of plaintiff's application for disability insurance benefits and supplemental security income. The court held that good reasons and substantial evidence supported the ALJ's determination that plaintiff's claimed limitations were not entirely credible. In this case, the ALJ considered plaintiff's alleged limitations, and substantial evidence supported the ALJ's residual functional assessment. Finally, the district court properly denied plaintiff's request for another hearing. View "Nash v. Commissioner, Social Security Administration" on Justia Law

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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

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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