Goseland v. Social Security Administration Commissioner, 2:18-cv-02108

Plaintiff Betty Goseland filed for DIB alleging onset 11/28/2014 from neuropathy, headaches, nausea, back pain, and depressive/anxiety symptoms; claim denied and ALJ conducted hearing 8/24/2016.
ALJ found severe impairments (lumbago, peripheral neuropathy, headaches, obesity, post-mastectomy/chemotherapy effects, major depressive disorder/unspecified anxiety) but not disabling and assessed an RFC for limited light work (restrictions on climbing, frequent handling/fingering, no driving, simple/rote tasks).
VE testimony supported three representative occupations existing in significant numbers nationally; ALJ concluded not disabled from 11/28/2014 through decision date.
Relevant medical evidence included consultative psychological and neurological exams, treating records (primary care, oncology, ENT, GI), EMG/NCS studies without definitive large-fiber neuropathy, sinus surgery with symptom improvement, and treating physician Guthrey’s checkbox opinion imposing severe limitations (e.g., >4 absences/month, no repetitive hand use).
Appeals Council denied review; magistrate judge recommended affirming the ALJ, finding the record sufficiently developed, the symptom analysis proper, and the RFC supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ failed to fully develop the record	Goseland: ALJ should have obtained further clarification from consultative examiner about concentration/ sequencing limits in work settings	Berryhill: record sufficiently developed; doctor opinions about work capacity are for the Commissioner	ALJ not required to obtain more opinions; record was reasonably complete and ALJ considered consultative findings (gave them some weight)
Whether ALJ improperly discounted subjective symptoms	Goseland: ALJ relied improperly on lack of objective findings and misapplied standards (cites rescinded SSR 96-7p)	Berryhill: ALJ applied Polaski factors, considered daily activities, treatment, objective findings, medication effects	ALJ properly evaluated symptoms, considering medical evidence, activities, treatment history, and symptom consistency
Whether ALJ erred in rejecting treating physician Guthrey’s limitations	Goseland: Guthrey’s medical source statement supports more restrictive RFC (limited lifting, no repetitive hand use, frequent absenteeism)	Berryhill: Guthrey’s checkbox form is conclusory, inconsistent with objective record and Guthrey’s own notes	ALJ reasonably gave Guthrey’s checklist little weight; RFC supported by overall record and other medical opinions

Vossen v. Astrue, 612 F.3d 1011 (8th Cir. 2010) (substantial-evidence standard)
Teague v. Astrue, 638 F.3d 611 (8th Cir. 2011) (definition of substantial evidence)
Johnson v. Astrue, 627 F.3d 316 (8th Cir. 2010) (ALJ need order additional tests only if record insufficient)
Page v. Astrue, 484 F.3d 1040 (8th Cir. 2007) (RFC may be supported without treating physician RFC form)
Anderson v. Astrue, 696 F.3d 790 (8th Cir. 2012) (conclusory checkbox opinions carry little evidentiary weight)