Carrie Andrews v. Carolyn W. Colvin
791 F.3d 923
| 8th Cir. | 2015Background
- Andrews (b. 1976) applied for DIB and SSI alleging disability from October 23, 2007, due to fibromyalgia/chronic pain, cervical disc disease, migraines, depression/anxiety, and borderline personality disorder.
- Treating physician Dr. Wandal Money submitted a medical source statement limiting Andrews to <10 lb lifting, <2 hours standing/walking, <4 hours sitting, frequent breaks/position changes, limited hand use, avoidance of environmental exposures, and >4 absences/month.
- State agency consultants (physician and psychologists) concluded Andrews could perform sedentary work with postural limits, limited environmental exposure, simple/rote tasks, incidental interpersonal contact, and simple/direct supervision; one psychologist examined Andrews in person.
- ALJ gave little weight to Dr. Money’s MSS, credited the state consultants, found Andrews had the RFC for a limited range of sedentary work (could not perform past work), and relied on a VE who identified document preparer and call-out operator jobs.
- ALJ found Andrews not disabled; the Appeals Council denied review. The district court affirmed, and Andrews appealed to the Eighth Circuit challenging the ALJ’s discounting of Dr. Money’s opinion and Andrews’ subjective symptom testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly discounted treating physician opinion | ALJ improperly rejected Dr. Money’s MSS which would establish disability | ALJ permissibly gave little weight because MSS was inconsistent with record and treatment notes | Affirmed: ALJ provided adequate reasons and substantial evidence supported discounting MSS |
| Whether ALJ properly assessed Andrews’ credibility about pain/limitations | Andrews’ testimony of disabling pain should have been credited | ALJ properly found subjective reports inconsistent with medical records, activities, demeanor, and noncompliance | Affirmed: ALJ’s credibility findings supported by substantial evidence |
| Whether RFC finding was supported by substantial evidence | RFC failing to incorporate Dr. Money’s limitations was unsupported | RFC supported by state agency opinions and other record evidence | Affirmed: RFC supported by substantial evidence, VE testimony supported nondisability |
| Whether ALJ erred in applying legal standards for treating-source and credibility analysis | ALJ misapplied standards and overstated Dr. Money’s reliance on subjective complaints | ALJ applied proper legal standards and gave adequate reasons despite one overstatement | Affirmed: any overstatement was harmless; overall analysis met legal requirements |
Key Cases Cited
- Toland v. Colvin, 761 F.3d 931 (8th Cir. 2014) (standard for reviewing whether ALJ decision is supported by substantial evidence)
- Cline v. Colvin, 771 F.3d 1098 (8th Cir. 2014) (treating physician opinion weight and requirement to give good reasons)
- Hacker v. Barnhart, 459 F.3d 934 (8th Cir. 2006) (five-step sequential evaluation framework)
- Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (claimant bears burden to establish RFC)
- Cox v. Barnhart, 471 F.3d 902 (8th Cir. 2006) (standards for discounting subjective pain testimony)
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for evaluating claimant credibility)