4:19-cv-04026
W.D. Ark.Dec 30, 2019Background
- Plaintiff Virginia Clayton protectively filed for DIB on March 10, 2016, alleging an onset date of June 2, 2014.
- Claimed impairments included fibromyalgia, chronic migraines, plantar fasciitis (right foot), lumbar degenerative disc disease, and multiple other conditions.
- ALJ found Clayton’s date last insured was March 31, 2018, and that her severe impairments were fibromyalgia, right plantar fasciitis, lumbar degenerative disc disease, and migraines.
- ALJ assessed an RFC for light work with occasional climbing (ramps/stairs and ladders/ropes/scaffolds) and occasional balancing, stooping, kneeling, crouching, and crawling.
- ALJ concluded Clayton could perform her past relevant work as a high school teacher and alternative jobs in the national economy, and therefore was not disabled from June 2, 2014 through March 31, 2018.
- Appeals Council denied review; the district court reviewed the record, found substantial evidence supported the ALJ’s decision, and affirmed, dismissing the complaint with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly evaluated Clayton's subjective symptom allegations | Clayton argued the ALJ discounted her symptom testimony improperly and failed to credit limitations | Saul argued the ALJ reasonably weighed the medical record and credibility factors and gave supported reasons for discounting testimony | Court held ALJ’s credibility evaluation was supported by substantial evidence and affirmed |
| Whether RFC is supported by substantial evidence | Clayton argued the RFC did not account for all limiting effects of her impairments (e.g., fibromyalgia, migraines, foot pain) | Saul argued the RFC reflects supported limitations consistent with the record and treating evidence | Court held record supports the ALJ’s RFC and affirmed |
| Whether ALJ’s hypothetical to the VE was proper | Clayton argued the VE hypothetical omitted limitations and therefore vocational findings are unreliable | Saul argued the hypothetical accurately reflected the RFC and supported VE testimony | Court held the hypothetical matched the RFC supported by substantial evidence; vocational findings upheld |
Key Cases Cited
- Cox v. Apfel, 160 F.3d 1203 (8th Cir. 1998) (claimant bears burden to prove disability lasting at least 12 months)
- Ramirez v. Barnhart, 292 F.3d 576 (8th Cir. 2002) (court reviews ALJ decision for substantial evidence)
- Edwards v. Barnhart, 314 F.3d 964 (8th Cir. 2003) (ALJ decision must be affirmed if supported by substantial evidence)
- Haley v. Massanari, 258 F.3d 742 (8th Cir. 2001) (court will not reverse simply because record could support contrary outcome)
- Young v. Apfel, 221 F.3d 1065 (8th Cir. 2000) (if two inconsistent positions can be drawn, ALJ’s supported position must be upheld)