Kathleen J. Papesh v. Carolyn W. Colvin
786 F.3d 1126
| 8th Cir. | 2015Background
- Papesh seeks disability benefits and SSI; ALJ denied, court reverses and remands.
- Treating physician Dr. Cash treated Papesh from 2009; Dr. Danielson and later Dr. Handrich provided assessments.
- MRI showed multilevel changes with mild disc desiccation but no severe impingement; Papesh reported chronic low back pain and leg radiation.
- Papesh had fibromyalgia and depression/anxiety; narcotics were used; functional reports describe limited daily activity.
- ALJ relied on Dr. Larson’s checklist opinion for light work; discounted Drs. Cash and Danielson; denied grid-rule disability.
- Hearing included neutral experts (Horozaniecki, Rutenbeck) and medical testimony; remand urged for proper evaluation under grid rule 201.14 as applicable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly weighed treating opinions. | Papesh’s doctors (Cash, Danielson) provide authoritative, consistent RFCs. | ALJ appropriately weighed opinions against record evidence. | ALJ erred in weight assignment; treating opinions entitled substantial weight and not properly discounted. |
| Whether nonexamining Larson’s light-work RFC was properly given substantial weight. | Larson’s checklist opinion lacks substantial support and conflicts with treating-source opinions. | Larson’s findings were supported by record. | ALJ erred in giving Larson substantial weight; opinion not sufficiently supported. |
| Whether the ALJ properly evaluated Papesh’s credibility and subjective pain claims. | Daily functioning reports corroborate significant limitations. | Credibility discredited due to activities and treatment response. | Credibility assessment flawed; subjective pain supported functional restrictions. |
| Whether Grid Rule 201.14 applies and requires a finding of disability. | Rule appears applicable given sedentary limitation, age, education, and skills. | Transferability and other factors negate automatic disability finding. | Grid Rule analysis to be remanded for proper application. |
Key Cases Cited
- Wagner v. Astrue, 499 F.3d 842 (8th Cir. 2007) (treating opinions deserve substantial weight when consistent with record)
- Leckenby v. Astrue, 487 F.3d 626 (8th Cir. 2007) (substantial evidence from multiple consistent RFC opinions warrants remand)
- Buckner v. Astrue, 646 F.3d 549 (8th Cir. 2011) (deference to ALJ; remand when necessary for proper analysis)
- Phillips v. Astrue, 671 F.3d 699 (8th Cir. 2012) (defining substantial evidence standard and RFC framework)
- McCoy v. Astrue, 648 F.3d 605 (8th Cir. 2011) (checklist format opinions; weight considerations)