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