Articles Posted in US Court of Appeals for the Eighth Circuit

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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

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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

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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

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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