Bryce Mabry v. Carolyn W. Colvin
815 F.3d 386
| 8th Cir. | 2016Background
- Plaintiff Bryce Mabry applied for DIB and SSI alleging schizoaffective disorder, depression, panic attacks, and morbid obesity; last worked March 2011 and amended onset to January 15, 2010.
- Medical records from Mid‑South (2004–2012) showed prior hospitalizations (2004, 2006, 2007), ongoing therapy and medication, but stabilization and improvement from 2010–2012 with reported absence of hallucinations/delusions in 2012.
- June 2011 consultative examiner Dr. Samuel Hester diagnosed schizoaffective disorder and opined Mabry was unlikely to cope with typical work demands, but also observed controlled psychosis and capacity to complete tasks if motivated.
- Two non‑examining state psychiatric reviewers concluded Mabry could perform simple, routine, repetitive tasks with limited interpersonal contact and simple, direct supervision.
- At an administrative hearing a vocational expert testified a person with Mabry’s RFC could perform past unskilled jobs and other unskilled work; the ALJ adopted an RFC limiting Mabry to simple, routine, repetitive tasks with incidental interpersonal contact and simple direct supervision and denied benefits.
- The district court affirmed; on appeal the Eighth Circuit reviewed whether the ALJ’s RFC (limiting Mabry to unskilled work) was supported by substantial evidence and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RFC limiting Mabry to simple, routine, repetitive tasks adequately accounts for his mental impairments | Mabry: ALJ ignored voluminous Mid‑South records, hospitalizations, ongoing suicidal ideation, panic attacks, and relied mainly on non‑examining consultants; RFC too favorable | Commissioner: ALJ considered the longitudinal record, consistent state‑agency opinions, consultative exam, treatment notes showing stabilization, and appropriately weighed evidence | Affirmed: ALJ’s RFC supported by substantial evidence given treatment progress, consultative findings, state reviewers, and claimant reports that meds were effective |
| Whether ALJ improperly discounted Dr. Hester’s opinion that Mabry could not cope with work demands | Mabry: Dr. Hester (examiner) said Mabry unlikely to cope; ALJ should have credited this | Commissioner: ALJ may discount inconsistent parts of an examiner’s opinion and relied on other consistent findings within Dr. Hester’s report | Affirmed: ALJ permissibly rejected the isolated, internally inconsistent statement as inconsistent with the remainder of Dr. Hester’s report |
| Whether ALJ improperly relied on the absence of explicit work restrictions from treating providers | Mabry: Treating clinicians were not asked about work capacity; their silence cannot support RFC | Commissioner: ALJ mentioned lack of restrictions but did not base RFC solely on that; he relied on multiple record sources | Affirmed: ALJ did not rely solely on silence; RFC grounded in overall evidence |
| Whether periods of improvement/medication control foreclose finding of disability | Mabry: Remissions are inherent in psychotic illnesses and do not prove non‑disability | Commissioner: Evidence shows medications and therapy controlled symptoms sufficiently for unskilled work during relevant period | Affirmed: ALJ properly considered medication effectiveness and longitudinal record in concluding limitations compatible with unskilled work |
Key Cases Cited
- Johnson v. Colvin, 788 F.3d 870 (8th Cir.) (standard of review; substantial evidence)
- Partee v. Astrue, 638 F.3d 860 (8th Cir.) (RFC must consider all impairments and be based on medical evidence)
- Cox v. Astrue, 495 F.3d 614 (8th Cir.) (RFC as medical question; ALJ must support RFC with medical evidence)
- Pearsall v. Massanari, 274 F.3d 1211 (8th Cir.) (claimant bears burden to establish RFC; poor work history may indicate lack of motivation)
- Stormo v. Barnhart, 377 F.3d 801 (8th Cir.) (proper to rely in part on state agency consultants)
- Perks v. Astrue, 687 F.3d 1086 (8th Cir.) (ALJ may discount physician opinion that is internally inconsistent)
- Pate‑Fires v. Astrue, 564 F.3d 935 (8th Cir.) (GAF scores may be relevant but not controlling)