Background

• Plaintiff Centeeria Bowman filed an application for Disability Insurance Benefits (DIB) on May 10, 2023, alleging disability from PTSD, sciatica, depression, anxiety, panic attacks, and limited left ankle movement, with an onset date of December 31, 2020.
• Plaintiff's claim was denied initially and on reconsideration; a hearing was conducted before an ALJ on March 14, 2024.
• The ALJ found Bowman had severe impairments but that these did not meet or equal a listed impairment; she was not engaged in substantial gainful activity and had not performed past relevant work since the alleged onset date.
• The ALJ determined Plaintiff could perform light work with significant limitations and identified jobs in the national economy that Bowman could perform (price marker, housekeeper, router).
• Plaintiff's appeal contended that the ALJ failed to properly assess her mental functional limitations and did not adequately develop the record.
• The district court reviewed the case and found substantial evidence supporting the ALJ’s decision, affirming the denial of benefits and dismissing Bowman's complaint with prejudice.

Issues

Key Cases Cited

• Ramirez v. Barnhart, 292 F.3d 576 (8th Cir. 2002) (defining substantial evidence standard for review of Social Security decisions)
• Johnson v. Apfel, 240 F.3d 1145 (8th Cir. 2001) (clarifying threshold for substantial evidence in disability cases)
• Haley v. Massanari, 258 F.3d 742 (8th Cir. 2001) (requiring affirmance when ALJ’s findings are supported by substantial evidence)
• Young v. Apfel, 221 F.3d 1065 (8th Cir. 2000) (affirming ALJ when evidence could support two conclusions)
• Edwards v. Barnhart, 314 F.3d 964 (8th Cir. 2003) (upholding ALJ's findings where supported by substantial evidence)
• Cox v. Apfel, 160 F.3d 1203 (8th Cir. 1998) (burden on claimant to prove disability lasting at least 12 months)