Erickson v. Commissioner of Social Security, 5:24-cv-04010

Plaintiff Brian E. (born 1991, high school graduate) alleged disability from May 5, 2020, mainly due to a back injury with spinal fusion, nerve damage, depression, and PTSD.
Applied for Disability Insurance Benefits (DIB) under Title II of the Social Security Act; initial application and reconsideration were denied.
After the December 2021 unfavorable ALJ decision, the Appeals Council remanded for further RFC consideration; a second hearing led to another unfavorable ALJ decision in August 2023.
Appeals Council denied review, making the ALJ’s decision final; Plaintiff sought judicial review in federal court.
The case was referred to a magistrate judge for a report and recommendation.

Issue	Plaintiff's Argument	Defendant's Argument	Held (Court's Ruling)
1. RFC – Stress Level	ALJ failed to properly define/evaluate "low stress" jobs individualized to plaintiff's symptoms	RFC definition matches precedent; Plaintiff offered no specific evidence needing additional restrictions	ALJ’s RFC limitation to low stress jobs is affirmed
2. "Paragraph B" Criteria for Mental Impairments	ALJ did not provide adequate rationale or identify specific limitations per the regulations	ALJ applied regulations, cited evidence, and findings are supported by substantial evidence	ALJ’s evaluation affirmed; decision supported by record
3. Evaluation of Maximum Exertional RFC	ALJ’s "light work" finding unsupported/misleading; didn’t properly consider Plaintiff’s functional evidence	Decision based on comprehensive assessment of evidence and record, not mere disagreement	ALJ’s RFC finding supported by substantial evidence
4. Reliance on Vocational Expert (VE) Testimony & DOT Conflicts	VE testimony was conflicting and unresolved with the DOT; ALJ failed to address inconsistencies	Eighth Circuit precedent allows for jobs cited; no unresolved conflict as argued	ALJ properly relied on VE testimony; no conflict found

Swink v. Saul, 931 F.3d 765 (8th Cir. 2019) (explains five-step sequential evaluation for disability claims)
Moore v. Astrue, 572 F.3d 520 (8th Cir. 2009) (burden-shifting framework in disability cases)
Guilliams v. Barnhart, 393 F.3d 798 (8th Cir. 2005) (ALJ’s decision must be upheld if supported by substantial evidence even if inconsistent conclusions may be drawn)
Casey v. Astrue, 503 F.3d 687 (8th Cir. 2007) (RFC determinations must have some medical support in the record)
Renfrow v. Astrue, 496 F.3d 918 (8th Cir. 2007) (no conflict between "simple, concrete instructions" and reasoning level 3 jobs)
Hillier v. Soc. Sec. Admin., 486 F.3d 359 (8th Cir. 2007) (limitations to unskilled work are generally consistent with level 2 reasoning jobs)
Cox v. Astrue, 495 F.3d 614 (8th Cir. 2007) (ALJ has duty to develop record fully and fairly)