James Stringer v. Nancy A. Berryhill, 700 F. App'x 566

James Bret Stringer appealed the denial of Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI) after an ALJ denied benefits in February 2013.
The district court affirmed the denial; Stringer sought appointed counsel and a default judgment below and on appeal challenged the ALJ’s credibility findings, RFC assessment, failure to order a second consultative exam, and alleged ALJ bias.
The magistrate judge’s decision was reviewed by the panel; review of the denial of counsel and default entry was for abuse of discretion, and benefits denial was reviewed de novo with substantial-evidence review of the ALJ’s factual findings.
The ALJ made an adverse credibility determination, found an RFC supported by the record (with no treating medical-opinion controlling the RFC), and declined to order an additional consultative examination.
The court emphasized that Stringer bore the burden to establish his RFC and to produce evidence to overcome the presumption of ALJ impartiality.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of appointed counsel	Stringer argued he needed counsel appointed	Defendant argued no right to counsel in civil SSA appeal and judge did not abuse discretion	No abuse of discretion; denial affirmed
Entry of default judgment	Stringer argued default should be entered	Defendant argued it failed to meet Fed. R. Civ. P. 55(a) standard	Denial affirmed; no default because defendant defended
Credibility finding	Stringer argued ALJ improperly discounted his testimony	Defendant argued ALJ gave valid reasons and is entitled to deference	Credibility determination upheld as supported by valid reasons and substantial evidence
Failure to order additional consultative exam	Stringer argued record was incomplete and required more testing	Defendant argued medical record was sufficient and no unfair prejudice	No error; ALJ not required to order further exams absent insufficient evidence
RFC assessment without medical opinion	Stringer argued RFC lacked support without specific medical opinion	Defendant argued RFC may be supported by record evidence and claimant bears burden	RFC sustained; supported by substantial evidence and claimant’s burden to prove limitations
Alleged ALJ bias	Stringer claimed the ALJ was biased	Defendant argued presumption of ALJ impartiality stands absent strong evidence	Claim rejected; insufficient evidence to overcome presumption of impartiality

Phillips v. Jasper County Jail, 437 F.3d 791 (8th Cir.) (factors for appointment of counsel in civil cases)
Taylor v. City of Ballwin, 859 F.2d 1330 (8th Cir.) (default judgment standard and abuse-of-discretion review)
Gann v. Berryhill, 864 F.3d 947 (8th Cir.) (substantial-evidence standard for SSA benefits denials)
Julin v. Colvin, 826 F.3d 1082 (8th Cir.) (deference to ALJ credibility findings if supported by good reasons)
Halverson v. Astrue, 600 F.3d 922 (8th Cir.) (ALJ need not discuss every credibility factor so long as considered)
Martise v. Astrue, 641 F.3d 909 (8th Cir.) (ALJ must order additional medical exams only when record is insufficient)
Shannon v. Chater, 54 F.3d 484 (8th Cir.) (remand for failure to develop record required only if unfair or prejudicial)
Boyd v. Colvin, 831 F.3d 1015 (8th Cir.) (RFC is ALJ responsibility and must be based on all relevant evidence)
Hensley v. Colvin, 829 F.3d 926 (8th Cir.) (RFC must be grounded in medical evidence but need not be from a specific medical opinion)
Perkins v. Astrue, 648 F.3d 892 (8th Cir.) (claimant bears burden to overcome presumption of ALJ impartiality)