Hagemeier v. Commissioner of Social Security
6:14-cv-02051
N.D. IowaJun 4, 2015Background
- Plaintiff Dane A. Hagemeier (b. 1989) applied for SSI alleging disabling mental impairments (depression, anxiety/social phobia, personality disorder, substance abuse history, ADHD) and limited ability to work; ALJ found no past relevant work but noted part‑time work through Goodwill.
- Consultative and agency evaluations diagnosed depressive disorder, social phobia, personality features, and history of polysubstance abuse; state reviewers found moderate limitations but ability to do simple, low‑stress work with minimal public contact.
- Treating psychiatrist Dr. Marvin Piburn completed a 2012 RFC checklist assigning marked to extreme limitations (e.g., inability to sustain routine, interact, or tolerate supervision); treatment notes showed periodic improvement on medications and a GAF ~55.
- At hearing, plaintiff testified he could not work full time due to focus, depression, anxiety; vocational expert identified unskilled jobs consistent with a low‑stress, no‑public‑contact RFC, but testified that frequent absenteeism from substance use would preclude employment.
- ALJ adopted an RFC allowing work at all exertional levels but with: lower stress, no public contact, limited coworker contact, and tasks more than routine but less than complex; ALJ denied benefits and the district court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight accorded to treating psychiatrist (Dr. Piburn) | ALJ failed to give controlling/adequate weight to Dr. Piburn's extreme/marked limitations and should remand. | ALJ permissibly discounted checklist opinion as inconsistent with longitudinal records, treatment notes (improvement on meds), and internal inconsistencies. | Court: ALJ gave "good reasons" and properly afforded little weight to Dr. Piburn; no remand. |
| Credibility of subjective complaints | ALJ improperly discounted Hagemeier's testimony about severity/limitations. | ALJ’s credibility finding was supported by inconsistencies: treatment noncompliance, continued substance use, activities, part‑time work and consultative findings. | Court: ALJ considered Polaski factors, detailed inconsistencies, and credibility determination is supported. |
| RFC and record development (including ADHD) | ALJ’s RFC is unsupported: failed to treat ADHD as severe, relied too much on non‑examining reviewers, and did not fully develop illegible treatment notes. | Record shows ADHD diagnosed and treated with medication with little evidence it limited work; ALJ considered treating opinions and the record was adequately developed. | Court: RFC is supported by substantial evidence and record was fully and fairly developed; no remand. |
Key Cases Cited
- Anderson v. Astrue, 696 F.3d 790 (8th Cir. 2012) (standard of substantial evidence review)
- Vester v. Barnhart, 416 F.3d 886 (8th Cir. 2005) (court reviews whole record but does not reweigh evidence)
- Travis v. Astrue, 477 F.3d 1037 (8th Cir. 2007) (treating physician opinion assessed against record as a whole)
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for evaluating claimant's subjective complaints)
- Guilliams v. Barnhart, 393 F.3d 798 (8th Cir. 2005) (ALJ decision falls within zone of choice when supported by substantial evidence)