911 F.3d 550
8th Cir.2018Background
- Jeffrey Walker applied for Social Security disability benefits (Titles II and XVI) alleging onset October 25, 2011, due to degenerative disc disease, diabetes, and obesity.
- Treating physician Dr. Pratapji Thakor (ongoing care from 2013) noted limited cervical/thoracic/lumbar range of motion on MRIs and repeatedly opined Walker should avoid bending forward and lifting any weight; by Dec. 2015 he reported difficulty lifting >10 pounds.
- ALJ held a March 2016 hearing, found Walker had severe impairments but not per Listing, and assessed an RFC for limited sedentary work (sitting 6–8 hrs, standing/walking ≤2 hrs, lifting 10 lbs frequently/30 lbs occasionally, limited posturals, frequent reaching/handling).
- ALJ relied on a single consultative exam by neurosurgeon Dr. Tim Maryanov and state non-examining physicians; ALJ did not discuss Dr. Thakor’s written functional restrictions.
- Vocational expert testified Walker could not do past work but could perform other jobs (e.g., telephone order clerk); ALJ denied benefits.
- District court affirmed; the Eighth Circuit reversed and remanded because the ALJ failed to give good reasons for discounting the treating physician’s opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly weighed treating physician opinion | Walker: ALJ ignored Dr. Thakor’s treating-opinion restrictions (no bending, no lifting) and failed to give good reasons for discounting them | Gov’t: ALJ reasonably relied on consultative and state agency opinions and the record as whole, so specific discussion of the treating opinion wasn’t required | Court: ALJ erred—must give specific, good reasons for rejecting treating physician; ALJ failed to address Thakor’s restrictions and thus reversible error |
| Whether non-treating opinions can constitute substantial evidence against treating opinion | Walker: Non-treating opinions alone cannot outweigh a treating doctor without explanation | Gov’t: ALJ’s reliance on Dr. Maryanov and others provided substantial evidence | Court: Non-treating opinions do not, by themselves, constitute substantial evidence when conflicting with treating opinion absent adequate ALJ explanation |
| Whether objective evidence supported treating opinion | Walker: MRIs and clinical findings supported Dr. Thakor’s restrictions | Gov’t: ALJ credited MRI findings differently and emphasized consultative examiner’s near-normal findings | Court: MRIs were objective support for Thakor; ALJ acknowledged MRIs but did not reconcile or explain rejecting Thakor’s restrictions |
| Remedy for ALJ’s failure to provide reasons | Walker: Remand for proper consideration and articulation | Gov’t: Affirmance is appropriate because ALJ considered the record as a whole | Court: Reverse and remand to ALJ for further proceedings consistent with opinion |
Key Cases Cited
- Boettcher v. Astrue, 652 F.3d 860 (8th Cir. 2011) (standard of review for appeals from denials of Social Security benefits)
- Singh v. Apfel, 222 F.3d 448 (8th Cir. 2000) (ALJ must give good reasons and explain rejection of treating physician opinion)
- Kelley v. Callahan, 133 F.3d 583 (8th Cir. 1998) (consultative physician opinion from single exam generally insufficient as substantial evidence against treating opinion)
- Reece v. Colvin, 834 F.3d 904 (8th Cir. 2016) (treating physician opinions receive special weight; ALJ must give good reasons for discounting)