Collins v. Astrue
648 F.3d 869
8th Cir.2011Background
- Collins applied for disability insurance benefits on October 30, 2006.
- Initial and reconsidered denials led Collins to request a hearing before an ALJ.
- The ALJ found Collins not disabled, with RFC for sedentary work and credibility issues regarding pain.
- The ALJ concluded Collins could perform past work or other sedentary jobs with transferable skills.
- The Appeals Council denied review; the district court affirmed; Collins appealed to the Eighth Circuit.
- The court reversed and remanded for further proceedings consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ commit legal error in the step-five analysis? | Collins argues the ALJ failed to use the Grids or a VE without proper hypothetical. | Collins contends the ALJ could rely on Grids or a VE; district court error was harmless. | ALJ failed to follow proper step-five procedures; remand required. |
| Did the ALJ properly handle Collins' nonexertional impairments? | Collins argues nonexertional impairments (pain) require VE testimony and a proper hypothetical. | Commissioner asserts no reversible error given potential Grid direction. | Failure to obtain VE or reference Grids constitutes error; remand needed. |
| Was the ALJ's vocational assessment supported by substantial evidence? | VE testimony was not properly framed to reflect Collins' limitations. | Grids or proper VE testimony would support denial if used correctly. | Not supported given procedural defects; remand. |
Key Cases Cited
- Lowe v. Apfel, 226 F.3d 969 (8th Cir. 2000) (legal standard for reviewing disability determinations)
- Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (requires five-step sequential evaluation)
- Ellis v. Barnhart, 392 F.3d 988 (8th Cir. 2005) (grids relied upon when nonexertional impairments do not limit RFC)
- Baker v. Barnhart, 457 F.3d 882 (8th Cir. 2006) (nonexertional impairments require VE testimony, not grids alone)
- Cox v. Astrue, 495 F.3d 614 (8th Cir. 2007) (properly phrased hypothetical essential for VE testimony)
- Juszczyk v. Astrue, 542 F.3d 626 (8th Cir. 2008) (legal error review—de novo)
- Brueggemann v. Barnhart, 348 F.3d 689 (8th Cir. 2003) (error in applying legal standards in disability analysis)
- Nettles v. Schweiker, 714 F.2d 833 (8th Cir. 1983) (legal error in disability determinations)
- Hepp v. Astrue, 511 F.3d 798 (8th Cir. 2008) (nonbinding deficiencies may not affect outcome)