Combs v. Astrue
4:10-cv-00825
W.D. Mo.Dec 19, 2011Background
- Plaintiff William Combs, Jr. appeals SSA denial of SSI and SSDI (Final Decision review under 42 U.S.C. §§ 1383(c)(3), 405(g)).
- ALJ found not disabled after evaluating credibility, RFC, and vocational expert input.
- Plaintiff testified to neck/back pain, numbness, poor sleep, limited dexterity, and difficulty with standing, walking, and lifting.
- Plaintiff had prior work as truck driver, street sweeper, and pizza place worker; surgeries include cervical fusion and lumbar laminectomy.
- Treating records show multiple surgeries, extensive therapy history, edema/carpal tunnel issues, and nerve condition; however, objective findings led to RFC for sedentary work with limitations.
- Court affirms the ALJ, concluding substantial evidence supports the non-disability finding and RFC restrictions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFC adequately identified and supported? | Combs argues RFC too restrictive or not adequately supported by record. | ALJ properly considered credible evidence and vocational input. | RFC supported by substantial evidence. |
| Credibility determination under Polaski framework? | ALJ improperly discounted credible pain complaints. | ALJ explained credibility assessment with Polaski factors. | ALJ appropriately articulated credibility findings. |
| Record development sufficient to determine disability? | Record needed further development given numerous surgeries. | Record adequate; expert testimony and medical records support RFC. | Record adequate; no obligation for further development. |
| Did vocational expert support available work within RFC? | Combs could perform more strenuous work despite limitations. | VE identified sedentary unskilled jobs compatible with RFC. | Yes, VE-supported sedentary work within RFC. |
Key Cases Cited
- Bowman v. Barnhart, 310 F.3d 1080 (8th Cir. 2002) (Polaski factors and credibility require explicit ALJ articulation)
- Lowe v. Apfel, 226 F.3d 969 (8th Cir. 2000) (express credibility determination required)
- Pearsall v. Massanari, 274 F.3d 1211 (8th Cir. 2001) (RFC based on all relevant evidence, medical and nonmedical)
- McKinney v. Apfel, 228 F.3d 860 (8th Cir. 2000) (RFC must consider all relevant credible evidence)
- Dukes v. Barnhart, 436 F.3d 923 (8th Cir. 2006) (substantial evidence review of disability denial)