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Gonzalez v. Social Security Administration Commissioner
6:14-cv-06070
W.D. Ark.
Apr 15, 2015
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Background

  • Plaintiff Gonzalez filed for SSI, DIB, and a period of disability on March 9, 2011, alleging onset April 2, 2009, with multiple impairments.
  • ALJ hearing occurred December 11, 2012 in Hot Springs, Arkansas; Plaintiff was represented and testified; VE testified.
  • ALJ found insured status through June 30, 2011, and that Plaintiff had several severe impairments but did not meet or equal Listings.
  • RFC limited Plaintiff to light work with specific restrictions (limited climbing, balancing, reaching with right arm, etc.) and limited ability to perform complex or hazardous tasks.
  • Appeals Council denied review February 26, 2014; Plaintiff sought judicial review, and the case was heard by a U.S. Magistrate Judge in 2015; the opinion remanded for Polaski-compliant credibility analysis.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the ALJ properly evaluated credibility under Polaski Plaintiff argues ALJ discounted credibility solely because of lack of objective support Gonzalez contends ALJ appropriately weighed Polaski factors and relied on substantial evidence Remand for Polaski-compliant credibility evaluation

Key Cases Cited

  • Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (requires explicit Polaski factors and credibility analysis)
  • Shultz v. Astrue, 479 F.3d 979 (8th Cir. 2007) (Polaski framework retained; additional factors discussed)
  • Cox v. Barnhart, 471 F.3d 902 (8th Cir. 2006) (affirms framework for evaluating credibility and substantial evidence)
  • Thomas v. Sullivan, 928 F.2d 255 (8th Cir. 1991) (pain credibility not dispositive; must assess functional impact)
  • Lowe v. Apfel, 226 F.3d 969 (8th Cir. 2000) (ALJ must acknowledge Polaski factors when discounting credibility)
  • Young v. Apfel, 221 F.3d 1065 (8th Cir. 2000) (requires reasoned credibility determinations when benefits denied)
  • Haley v. Massanari, 258 F.3d 742 (8th Cir. 2001) (discusses standard for reviewing credibility and substantial evidence)
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Case Details

Case Name: Gonzalez v. Social Security Administration Commissioner
Court Name: District Court, W.D. Arkansas
Date Published: Apr 15, 2015
Citation: 6:14-cv-06070
Docket Number: 6:14-cv-06070
Court Abbreviation: W.D. Ark.
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    Gonzalez v. Social Security Administration Commissioner, 6:14-cv-06070