Karl Wright v. Carolyn W. Colvin
789 F.3d 847
8th Cir.2015Background
- Claimant Karl William Wright (age ~50) applied for DIB and SSI alleging disability from back and knee pain and depression, with alleged onset April 14, 2010; ALJ denied benefits and district court affirmed.
- Medical record: MRIs and x-rays showing degenerative disc disease (L4-5, L5-S1), moderate-to-severe central canal narrowing at L4-5, and mild degenerative knee changes; examinations often showed full (5/5) motor strength and only mild radiographic degenerative changes at times.
- Treating/examining providers (Drs. Griggs and Russell) reported significant limitations (e.g., sitting/standing limited to 20–30 minutes, recumbent most of day); ALJ gave these opinions little weight as inconsistent with objective evidence.
- Claimant has obesity (BMI implied by 6'0", ~350 lbs.), diabetes, prior car accidents (1987, 2000), inconsistent treatment adherence (periods without care, refusal of meds/therapy).
- Mental health: evaluations by Dr. Dempsey (Psy.D.) and Dr. Morgan (Ph.D.) diagnosed adjustment disorder with depressed mood / mild limitations (GAF ~60); ALJ found mental impairment non-severe and did not include additional mental restrictions in the RFC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight given to examining/treating physicians' opinions (Drs. Russell, Griggs) | ALJ improperly discounted their opinions; mischaracterized Russell as nonexamining | ALJ permissibly assigned little weight because opinions were inconsistent with objective record | Affirmed: ALJ erred in labeling Russell nonexamining but substantial evidence supports discounting opinions as inconsistent with record |
| Credibility of claimant's testimony about pain/functional limits | ALJ wrongly discredited Wright's subjective pain testimony | ALJ permissibly discounted credibility based on inconsistent work history, daily activities, treatment noncompliance, and objective findings | Affirmed: ALJ credibility determination supported by substantial evidence |
| Severity and RFC impact of mental impairment (depression, GAF 60) | ALJ should have found depression severe and included limits from GAF=60 in RFC | Mental examiners found only mild limitations; GAF has no direct correspondence to SSA severity listings; non-specialist notes not controlling | Affirmed: ALJ reasonably found mental impairment non-severe and gave appropriate weight to mental evaluations |
| Consideration of the record as a whole (including obesity) | ALJ failed to consider whole record and combined effects (esp. obesity) | ALJ expressly considered obesity and combined effects when assessing RFC | Affirmed: ALJ considered the whole record and combined effects; no reversible error |
Key Cases Cited
- Juszczyk v. Astrue, 542 F.3d 626 (8th Cir. 2008) (standard for substantial evidence review)
- Perkins v. Astrue, 648 F.3d 892 (8th Cir. 2011) (ALJ may discount treating physician when inconsistent medical evidence exists)
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for evaluating subjective complaints)
- Shontos v. Barnhart, 328 F.3d 418 (8th Cir. 2003) (examining physician opinions generally entitled to greater weight)
- Halverson v. Astrue, 600 F.3d 922 (8th Cir. 2010) (GAF score interpretation and limitations)
- Heino v. Astrue, 578 F.3d 873 (8th Cir. 2009) (discussion of obesity in RFC analysis)
- Edwards v. Barnhart, 314 F.3d 964 (8th Cir. 2003) (credibility is primarily for the ALJ to decide)