Jeanie Lawrence v. Andrew Saul, 970 F.3d 989

Background

Lawrence (age 30) applied in April 2016 for DIB and SSI alleging onset March 23, 2016, for right arm/shoulder pain, neck/radicular symptoms, headaches, and right foot tendonitis.
Medical record showed mixed findings: shoulder MRI with mild rotator cuff/biceps changes, cervical MRI without clear nerve root impingement, normal 2015 nerve conduction studies, and a March 2017 MRI showing a subluxed ulnar nerve; conservative treatment predominated and shoulder surgery (arthroscopy with biceps tenodesis) occurred August 2016.
Many providers reported multi‑factor pain (shoulder tendinopathy, possible cervical radiculopathy, myofascial issues); examinations frequently showed full strength and generally good ROM despite reported pain.
ALJ found Lawrence had severe biceps tendinitis post‑arthroscopy, assigned an RFC for sedentary work prohibiting right‑upper‑extremity overhead reaching and limiting right upper‑extremity handling to no more than "frequent." Vocational expert identified two jobs she could perform (addresser; call‑out operator).
ALJ afforded little weight to a treating physician’s opinion that she could not return to work, rejected a state non‑examiner’s no‑severe‑impairment finding, and discounted some of Lawrence’s subjective symptom severity as inconsistent with the record.
The Appeals Council denied review; the district court affirmed. The Eighth Circuit affirmed, holding the ALJ’s decision was supported by substantial evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ's RFC (frequent right‑hand handling) is supported by substantial evidence	AL contends the ALJ relied too much on pre‑surgery evidence, ignored March 2017 MRI subluxed ulnar nerve, and failed to capture disabling cubital/carpal tunnel symptoms	ALJ relied on mixed record: normal earlier nerve studies, improvement after shoulder surgery, repeated conservative treatment recommendations, and objective findings of full strength/ROM	Affirmed — substantial evidence supports RFC limiting handling to frequent rather than disabling limits
Whether ALJ properly weighed treating and non‑examining opinions	AL says the ALJ improperly discounted treating Dr. Ball and failed to develop record	Commissioner: ALJ permissibly gave little weight to Dr. Ball for lack of explanation/limited treatment history and properly rejected the non‑examiner inconsistent with the record	Affirmed — ALJ’s weighing was permissible
Whether ALJ properly assessed Lawrence’s symptom testimony	AL argues ALJ undervalued daily‑activity testimony and pain reports	Commissioner: ALJ reasonably found subjective complaints inconsistent with objective findings, conservative treatment, and providers’ recommendations	Affirmed — ALJ’s symptom assessment supported by record consistency analysis
Whether vocational‑expert testimony and identified jobs support non‑disability	AL argues jobs may be too demanding given upper‑extremity limits	Commissioner: VE identified jobs, and one cited job requires only occasional handling (less demanding than RFC)	Affirmed — VE testimony and jobs support non‑disability finding

Key Cases Cited

Strongson v. Barnhart, 361 F.3d 1066 (8th Cir. 2004) (standard of appellate review for Social Security denials)
Combs v. Berryhill, 878 F.3d 642 (8th Cir. 2017) (substantial‑evidence standard and RFC must be supported by medical evidence)
Steed v. Astrue, 524 F.3d 872 (8th Cir. 2008) (RFC is a medical question informed by evidence)
Ellis v. Barnhart, 392 F.3d 988 (8th Cir. 2005) (Commissioner makes final RFC determination)
Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for assessing subjective complaints)
Lauer v. Apfel, 245 F.3d 700 (8th Cir. 2001) (must consider combined effect of impairments)
Tindell v. Barnhart, 444 F.3d 1002 (8th Cir. 2006) (ALJ resolves conflicting medical evidence)
Myers v. Colvin, 721 F.3d 521 (8th Cir. 2013) (conservative treatment and lack of physician‑imposed restrictions may undercut disability claim)
Moore v. Astrue, 572 F.3d 520 (8th Cir. 2009) (treatment course relevant to credibility of disabling complaints)
Owens v. Colvin, 727 F.3d 850 (8th Cir. 2013) (definitions of "frequent" and "occasional" in DOT relevant to RFC analysis)