David Martin v. Nancy A. Berryhill
698 F. App'x 856
| 8th Cir. | 2017Background
- David Martin appealed the denial of disability insurance benefits and SSI after an ALJ found him not disabled.
- The ALJ found Martin’s subjective pain complaints not entirely credible and assessed an RFC for less than a full range of sedentary work.
- A vocational expert (VE) testified that jobs exist nationally that Martin could perform given that RFC.
- Martin argued that any physical exertion exacerbates his condition and that he is therefore disabled or unable to perform the VE-identified jobs.
- The District Court affirmed the Commissioner’s decision; the Eighth Circuit panel likewise affirmed, finding substantial evidence supports the ALJ’s credibility finding, RFC assessment, and reliance on the VE.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility of subjective pain complaints | Martin: pain and exertion fully disabling; ALJ should credit his testimony | ALJ: claimant's allegations not fully credible based on record inconsistencies and medical evidence | ALJ credibility determination upheld; supported by multiple valid reasons and substantial evidence |
| RFC formulation | Martin: RFC should reflect disabling limitations from exertion | Commissioner: RFC properly based on medical evidence and overall record | RFC properly formulated and supported by medical evidence and record |
| Reliance on VE testimony | Martin: VE jobs identification may be unreliable if hypothetical omits true limitations | Commissioner: VE response valid because hypothetical included all limitations supported by record | Reliance on VE was proper because hypothetical incorporated supported impairments and limitations |
| Job availability vs. claimant's inability to find work locally | Martin: inability to find the VE-identified jobs means he remains unemployed and disabled | Commissioner: national job availability controls disability, not claimant's local job search success | Jobs existing in significant numbers nationally is dispositive; inability to find local work does not establish disability |
Key Cases Cited
- Perks v. Astrue, 687 F.3d 1086 (8th Cir. 2012) (standards of review for substantial evidence review)
- Casey v. Astrue, 503 F.3d 687 (8th Cir. 2007) (deference to ALJ credibility determinations when supported by valid reasons)
- Boyd v. Colvin, 831 F.3d 1015 (8th Cir. 2016) (ALJ responsible for RFC; VE testimony based on proper hypothetical constitutes substantial evidence)
- Hensley v. Colvin, 829 F.3d 926 (8th Cir. 2016) (RFC is a medical question and must be supported by medical evidence)
- Milam v. Colvin, 794 F.3d 978 (8th Cir. 2015) (VE testimony based on properly phrased hypothetical constitutes substantial evidence)