Curtis Igo v. Carolyn Colvin
839 F.3d 724
8th Cir.2016Background
- Curtis Igo applied for Title II disability insurance benefits alleging onset Sept. 1, 2009, based on hip osteoarthritis, degenerative disc disease, neuropathies, shoulder pain, and carpal tunnel; claim denied at all administrative levels and affirmed by district court.
- ALJ found Igo had not engaged in substantial gainful activity since the alleged onset date and identified several severe impairments (lumbar/cervical degenerative disc disease, bilateral hip osteoarthritis/degenerative joint disease, carpal tunnel, sensory neuropathy); mental impairments deemed nonsevere.
- ALJ determined Igo did not meet or equal any listed impairment (did not specify listings considered) and assessed an RFC for sedentary work.
- Based on that RFC, the ALJ concluded Igo could perform his past relevant work as a receptionist and was not disabled; Appeals Council denied review.
- Igo appealed, arguing (1) the ALJ should have found he met or equaled Listing 1.02A (major dysfunction of a joint) and (2) the ALJ erred in assessing his RFC, including discounting lay and treating opinions and his credibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Igo meets or equals Listing 1.02A (major dysfunction of a joint) | Igo says hip degenerative changes and combined spinal issues produce gross anatomical deformity and inability to ambulate effectively, satisfying Listing 1.02A or its equivalent | Commissioner argues record lacks evidence of a "gross anatomical deformity" visible without imaging and lacks evidence of inability to ambulate effectively; combination of impairments does not equal listing | Court upheld ALJ: substantial evidence supports that Igo lacked a gross anatomical deformity and could ambulate effectively; listing not met or equaled |
| Whether ALJ properly assessed RFC (position changes, concentration, keyboarding, reaching) | Igo contends ALJ failed to account for pain-driven limits: frequent position changes, concentration deficits, keyboard and reaching restrictions | Commissioner contends ALJ considered these limitations, discounted them with good reasons (inconsistent medical notes, work activity, normal strength/exam findings) | Court held ALJ did not err: he considered limitations, gave valid reasons to discount them, and RFC supported by substantial evidence |
| Whether ALJ properly weighed non-medical lay opinion (supervisor) | Igo asserts supervisor’s observations showed greater limitations and should have been given more weight | Commissioner points to SSR 06-03p and says ALJ permissibly discounted lay opinion as inconsistent with objective evidence and claimant’s activities | Court held ALJ reasonably discounted supervisor’s opinion given inconsistency with record and no requirement to give it controlling weight |
| Whether ALJ improperly rejected treating physician’s opinion that claimant was disabled | Igo argues treating physician’s opinion of disability should carry substantial weight | Commissioner notes treating opinion conflicted with more detailed medical evidence showing normal strength, reflexes, fine finger motion, and daily activities; ALJ may discount treating opinion when contradicted by better evidence | Court affirmed ALJ’s discounting of treating physician’s disability opinion as supported by substantial evidence |
Key Cases Cited
- Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (explains five-step sequential evaluation and RFC principles)
- Jones v. Astrue, 619 F.3d 963 (8th Cir. 2010) (claimant must meet all specified listing criteria)
- Boettcher v. Astrue, 652 F.3d 860 (8th Cir. 2011) (ALJ’s failure to identify a listing may be harmless if record supports overall conclusion)
- Carlson v. Astrue, 604 F.3d 589 (8th Cir. 2010) (medical equivalence requires findings equal in severity to all criteria of the most similar listing)
- Wildman v. Astrue, 596 F.3d 959 (8th Cir. 2010) (ALJ may discount treating physician’s opinion when other assessments are better supported)
- Pearsall v. Massanari, 274 F.3d 1211 (8th Cir. 2001) (ALJ decides credibility of subjective complaints)
- Perrin v. United States, 444 U.S. 37 (1979) (undefined regulatory terms are given ordinary meaning)