Bell v. Social Security Administration, 4:11-cv-01303

Plaintiff Jason Bell seeks judicial review of the SSA's denial of DIB and SSI benefits under 42 U.S.C. § 405(g).
Bell filed his claim on September 22, 2006, alleging disability from July 1, 2005; ALJ denied after hearing in May 2010; Appeals Council denied in June 2011.
Hearing before an ALJ included Bell (represented), and vocational expert; Bell testified to bipolar disorder, ADHD, migraines, seizures, and substantial daily impairments.
Medical records show pediatric absence seizures, ADHD, bipolar disorder, migraines, hypertension; several doctors provided evaluations and GAF scores around 65-70.
The ALJ found Bell not disabled, limited by mental and physical RFC to simple unskilled work with limited contact and no hazards, and credited vocational expert’s 36,000 Missouri hand-packager-like positions and related jobs.
Magistrate Judge recommends affirming the Commissioner's decision, concluding substantial evidence supports the RFC and credibility determinations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly weighed medical opinions	Bell argues Muddasani and Walker were misweighed.	ALJ properly weighed treating and consultative opinions in light of record; credibility and consistency considered.	Yes; ALJ properly weighed medical opinions.
Whether the RFC adequately reflects mental impairment limitations	Walker’s findings show marked limitations that would preclude work.	Record shows controlled bipolar disorder with medication; aggressive credibility assessment supports limited psychiatric restrictions but not disabling.	RFC supported by substantial evidence; limitations are adequate for the identified jobs.
Whether vocational expert testimony was required post-examiner	Post-hearing consultative findings by Walker necessitate VE input.	VE testimony already accounted for RFC; Walker’s limitations were not credible and would not alter VE conclusions.	No; VE testimony not required to affirm.

Ostronski v. Chater, 94 F.3d 413 (8th Cir. 1996) (Judicial review deferential; substantial evidence standard)
Roberts v. Apfel, 222 F.3d 466 (8th Cir. 2000) (Substantial evidence review; considering entirety of record)
Kelley v. Callahan, 133 F.3d 583 (8th Cir. 1998) (Substantial evidence suffices if reasonable mind could support)
Robinson v. Sullivan, 956 F.2d 836 (8th Cir. 1992) (Two inconsistent positions; weighing evidence)
Jones v. Callahan, 122 F.3d 1148 (8th Cir. 1997) (ALJ to address medical opinions; credibility assessment)