Baldwin v. Colvin
4:16-cv-00565
| E.D. Mo. | Sep 26, 2017Background
- Mark Baldwin applied for Disability Insurance Benefits (Title II) alleging onset March 9, 2012; application filed May 9, 2013; ALJ denied benefits on November 20, 2014 and Appeals Council denied review.
- ALJ found Baldwin met insured status through December 31, 2017, had engaged in substantial gainful activity through October 2012, and thereafter had at least a 12-month period of non‑SGA.
- ALJ found severe impairments: bipolar I disorder and personality disorder, but no listing-level impairment.
- ALJ assessed an RFC for full range of work at all exertional levels with non‑exertional limits: unskilled work, only occasional contact with supervisors/coworkers/public, occasional changes in work environment, and only occasional independent judgment.
- ALJ concluded Baldwin could not perform past relevant work but could perform jobs existing in significant numbers (e.g., sorter, laundry worker, hand packager); therefore not disabled.
- On appeal Baldwin argued the ALJ failed to properly weigh (1) psychologist Dr. Alan Politte’s opinion (including a GAF of 50) and (2) lay opinion/testimony of his mother, Rita Baldwin.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ failed to state weight given to psychologist Dr. Politte’s opinion | Baldwin: ALJ did not specify weight for Dr. Politte’s opinion (and GAF=50 suggests greater limitations) | Commissioner: ALJ considered the report, adopted limitations consistent with it, and permissibly discounted GAF scores; any omission as to explicit weight was harmless | Court: No reversible error — ALJ’s decision and RFC show Dr. Politte’s findings were considered; discounting GAF was permissible and explained; failure to state explicit weight was harmless |
| ALJ improperly discredited lay opinion of claimant’s mother (two sources: hearing testimony and Third Party Function Report) | Baldwin: ALJ failed to specify which of the two sources he assigned little weight and did not adequately explain discrediting | Commissioner: ALJ explicitly gave the mother’s testimony "little weight," the two sources were substantially similar, and the ALJ gave clear, permissible reasons (inconsistencies with claimant’s statements, activities, noncompliance, non‑medical reasons for stopping work) | Court: No reversible error — ALJ adequately addressed and discounted mother’s statements and tied that to credibility findings about claimant |
| RFC unsupported by substantial evidence due to opinion‑evaluation errors | Baldwin: Misweighing of medical and lay opinions renders RFC unsupported | Commissioner: Record as a whole supports RFC; ALJ analyzed medical evidence, credibility, and non‑medical statements | Court: Substantial evidence supports the RFC and non‑disability finding |
| Whether GAF score requires remand | Baldwin: GAF 50 indicates serious symptoms inconsistent with RFC | Commissioner: GAF lacks direct correlation to SSA listings and ALJ permissibly gave it little weight | Court: ALJ permissibly discounted GAF and articulated reasons; no remand required |
Key Cases Cited
- Goff v. Barnhart, 421 F.3d 785 (8th Cir.) (Describes the five‑step disability evaluation process)
- Krogmeier v. Barnhart, 294 F.3d 1019 (8th Cir.) (Defines substantial evidence standard)
- Ellis v. Barnhart, 392 F.3d 988 (8th Cir.) (Failure to state weight for opinion can be harmless if decision shows opinion was considered)
- Byes v. Astrue, 687 F.3d 913 (8th Cir.) (Claimant must show prejudice from ALJ error to warrant remand)
- Van Vickle v. Astrue, 539 F.3d 825 (8th Cir.) (Harmlessness standard for opinion‑weighing errors)
- Jones v. Astrue, 619 F.3d 963 (8th Cir.) (GAF scores do not have a direct correlation to SSA listings and may be discounted)
- Page v. Astrue, 484 F.3d 1040 (8th Cir.) (Step‑two severity standard and when evaluation may end)
- Lorenzen v. Chater, 71 F.3d 316 (8th Cir.) (ALJ need not list detailed reasons for discounting non‑medical opinion when reasons are evident)
- Sloan v. Astrue, 499 F.3d 883 (8th Cir.) (Lay witnesses, including parents, can provide relevant opinion evidence)
- Steed v. Astrue, 524 F.3d 872 (8th Cir.) (Claimant bears burden through step four to establish RFC)