Angela Myers v. Carolyn W. Colvin
721 F.3d 521
| 8th Cir. | 2013Background
- Myers, a former full-time nurse, worked part-time until March 2008, then claimed disability onset March 20, 2008 based on depression, anxiety, sleep apnea.
- Treating psychiatrist Dr. Horvath diagnosed dysthymic disorder, anxiety disorder NOS, and borderline personality disorder, with symptoms fluctuating with life stressors and responsive to medication.
- Dr. Horvath’s GAF estimates mostly indicated mild to moderate impairment; his July 2009 opinion claimed marked social and concentration difficulties with four or more decompensation episodes.
- August 2009 medical visit to Dr. Mace addressed shortness of breath; lifestyle plan included compression stockings and diet/exercise.
- SSA denied benefits initially and on reconsideration; an ALJ denied benefits at steps 1–5, determining medical equivalence and credibility, leading to denial of disability.
- Appeals Council later denied review based on additional hospitalization records after the ALJ decision, and district court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the impairment meets or equals Listing 12.04 | Myers argues medical equivalence via Dr. Horvath. | ALJ properly weighed evidence; no listing met. | No substantial evidence of equality or medical equivalence. |
| Whether Dr. Horvath's treating-physician opinion deserved controlling weight | Horvath’s opinion should be controlling. | Treating opinions not automatically controlling; inconsistent with record. | ALJ correctly discounted Horvath's opinion as inconsistent with record. |
| Whether the RFC adequately reflects physical limitations and obesity/breathing factors | ALJ failed to account for obesity and breathing restrictions. | Record supported light work RFC; no further development required. | RFC supported by substantial evidence; obesity/breathing considerations properly addressed. |
| Whether the credibility determination was legally sound | Myers' symptoms should be fully credible and disabling. | Credibility based on Polaski factors; consistent with medical and daily activity evidence. | No reversible error; credibility determination affirmed. |
Key Cases Cited
- Hacker v. Barnhart, 459 F.3d 934 (8th Cir. 2006) (treating opinions not inherently controlling when inconsistent with record)
- Prosch v. Apfel, 201 F.3d 1010 (8th Cir. 2000) (treating-source weight depends on consistency with evidence)
- Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (use of GAF in evaluating claimant's impairment is permissible)
- McKinney v. Apfel, 228 F.3d 860 (8th Cir. 2000) (RFC determination must be based on all relevant evidence)
- Samons v. Astrue, 497 F.3d 813 (8th Cir. 2007) (credibility analysis need not discuss every factor; rely on substantial evidence)
- Wiese v. Astrue, 552 F.3d 728 (8th Cir. 2009) (credibility when supported by RFC analysis)
- Flynn v. Chater, 107 F.3d 617 (8th Cir. 1997) (evidence of how new materials affect decision at review)