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