Kandi Cline v. Carolyn W. Colvin
771 F.3d 1098
8th Cir.2014Background
- Kandi Cline applied for SSI alleging disability due to back pain, fibromyalgia, and degenerative arthritis.
- Medical records show mixed imaging: 2005 CT with tiny L5-S1 disc protrusion; later MRIs largely normal.
- Treating and examining physicians (Drs. Campbell, Roberts, Knott, Cagle, Allen) offered varying opinions on functional limitations.
- Dr. Allen, a long-time treating physician, provided a March 2010 medical source statement limiting lifting, standing, and walking.
- ALJ found Cline capable of light work and able to perform past relevant work, discounting Dr. Allen’s opinion as inconsistent with the record.
- Appeals Council denied review; district court and appellate court upheld the denial of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight given to treating physician | Allen's opinion should be given controlling weight. | Allen’s opinion is inconsistent with record and less weight appropriate. | ALJ properly discounted Allen's opinion; substantial evidence supports denial. |
| Credibility of Cline's subjective complaints | Cline's complaints are credible and support greater limitations. | ALJ properly found credibility undermined by inconsistencies and exaggerations. | Credibility findings supported; did not compel disability finding. |
| Consistency with objective medical evidence | Record supports more severe limitations consistent with fibromyalgia. | Record contains substantial evidence supporting light work capability. | Court defers to ALJ's weighing; substantial evidence supports light work finding. |
Key Cases Cited
- Kirby v. Astrue, 500 F.3d 705 (8th Cir. 2007) (courts weigh conflicting medical opinions; credibility determinations given deference)
- Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (treating opinion may be discounted if inconsistent with record; require good reasons)
- Wildman v. Astrue, 596 F.3d 959 (8th Cir. 2010) (treating opinion not automatically controlling; consistency with records matters)
- Anderson v. Astrue, 696 F.3d 790 (8th Cir. 2012) (rejecting treating opinion only with substantial justification; must justify weight given)
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for evaluating credibility of subjective pain testimony)