Jody Hill v. Carolyn W. Colvin
753 F.3d 798
| 8th Cir. | 2014Background
- Hill, a former long-haul truck driver, applied for disability and SSI in 2007 after quitting due to stress.
- Diagnosed with depression, bipolar disorder, anxiety, and adjustment disorder; treatment included Celexa, lithium, and Prozac with mood improvement.
- ALJ denied benefits at initial hearing, finding Hill could return to past work with RFC limited to simple tasks and limited contact with others.
- Appeals Council remanded to reevaluate RFC, mental impairments, past work, and to obtain vocational expert input.
- On remand, ALJ reviewed mental impairments and RFC but did not hear vocational expert testimony, again finding Hill could return to his past work; Appeals Council denied further review.
- District court affirmed; Hill appeals the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ’s finding Hill could perform past work is supported by substantial evidence. | Hill argues RFC and past work analysis are unsupported. | Hill failed to show error; record supports past-work ability. | Yes; substantial evidence supports past-work finding. |
| Whether ALJ erred by not presenting vocational expert testimony on remand. | Remand required VE testimony to evaluate alternative work. | VE testimony unnecessary if step-four determination stands. | No; VE testimony not required when step-four basis remains valid. |
| Whether Appeals Council remand directives were properly addressed on remand. | ALJ did not follow remand directives fully. | ALJ complied by reevaluating RFC and past work. | Yes; remand directives were satisfied. |
Key Cases Cited
- McDade v. Astrue, 720 F.3d 994 (8th Cir. 2013) (de novo review of district court denial; substantial-evidence standard on underlying ALJ decision)
- Perks v. Astrue, 687 F.3d 1086 (8th Cir. 2012) (substantial-evidence review of ALJ determination)
- Juszczyk v. Astrue, 542 F.3d 626 (8th Cir. 2008) (legal-error review for failure to follow sequential evaluation)
- Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (legal-error standard for failure to follow sequential process)
- Lewis v. Barnhart, 353 F.3d 642 (8th Cir. 2003) (VE testimony required at step five when proceeding beyond step four)