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Evans v. Social Security Administration
5:16-cv-00021
E.D. Ark.
Oct 19, 2016
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Background

  • Evans applied for Social Security disability benefits with an August 26, 2011 alleged onset.
  • ALJ denied benefits; Appeals Council denied review; Evans appealed for judicial review.
  • ALJ found several severe impairments and set a reduced range of light work RFC, with specific lifting/carrying limits and non-exertional restrictions.
  • RFC allowed simple, rote tasks with incidental interpersonal contact and little independent judgment; limited to supervision and no interaction with the general public.
  • ALJ acknowledged a VA disability rating of 100% but held that VA findings are not binding and separately evaluated evidence to determine disability under the Social Security Act.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the VA 100% disability rating bound the SSA decision Evans argues VA rating requires great weight. Commissioner contends VA rating is not binding and independent SSA determination required. Not binding; SSA must independently determine disability.

Key Cases Cited

  • Hensley v. Colvin, 829 F.3d 926 (8th Cir. 2016) (VA finding not binding on SSA; require independent assessment)
  • Prosch v. Apfel, 201 F.3d 1010 (8th Cir. 2000) (standard for substantial evidence review)
  • Slusser v. Astrue, 557 F.3d 923 (8th Cir. 2009) (definition of substantial evidence)
  • McCartney v. Massanari, 298 F.3d 1072 (9th Cir. 2002) (great weight from other agency not binding; specific reasons needed)
  • Chambliss v. Massanari, 269 F.3d 520 (5th Cir. 2001) (similar principle across circuits)
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Case Details

Case Name: Evans v. Social Security Administration
Court Name: District Court, E.D. Arkansas
Date Published: Oct 19, 2016
Citation: 5:16-cv-00021
Docket Number: 5:16-cv-00021
Court Abbreviation: E.D. Ark.